IR 05000324/1993056
| ML20059B327 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/27/1993 |
| From: | Robert Carrion, Decker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059B280 | List: |
| References | |
| 50-324-93-56, 50-325-93-56, NUDOCS 9401040083 | |
| Download: ML20059B327 (14) | |
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UNITED STATES
/pa aro\ NUCLEAR REGULATORY COMMISSION p d- . . -k REGloN 11
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- ,.. S 101 MARIETT A STREET, N.W., SUITE 2900 y
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7,i ATLANTA GEORGIA 303234199
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Report Nos.: 50-325/93-56 and 50-324/93-56
Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 ,
Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 _j
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facility Name: Brunswick Nuclear Power Plant l
Inspection Conducted: November 29 - December 3, 1993 l Inspector: / 2 m R/ Pl Carrion, Radiation Specialist 2Date
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Approved by:\ k A?f T. R. Decker, Chief Date signed l Radiological Effluents and Chemistry Section l Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards i SUMMARY Scope: .
This routine, announced inspection was conducted in the areas of the organization of the Chemistry / Effluent Department, plant water chemistry, !
status of the Hydrogen Water Chemistry (HWC) Program, confirmatory measurements, the Post Accident Sampling System (PASS), the Standby Gas i Treatment System (SGTS), radioactive material processing and shipping, the transfer of contaminated onsite soil, and records for decommissioning plannin Results:
The Chemistry Department and the Radwaste Group were staffed by knowledgeable, I competent personnel (Paragraph 2). j Plant water chemistry was maintained well within Technical Specification (TS)- l limits (Paragraph 3). j The licensee was using HWC on Unit 2 and planned to use it on Unit I when it I restarted (Paragraph-4). )
9401040003 931229 PDR ADOCK 05000324 l G pon ,
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The licensee demonstrated that a good Counting Room radiochemical analysis program was in place for the detection of beta-emitting radionuclides (Paragraph.5).
The licensee had taken proactive measures to upgrade the PASS and was taking measures to assure that a PASS sample could be transported to an offsite laboratory for analysis in the event of an emergency (Paragraph .6).
The licensee had received qualified replacement seals for the fan shafts of the SGTS (Paragraph 7).
Radioactive material processing and shipping was conducted in a competent, professional manner (Paragraph 8).
The licensee had continued to place some slightly-contaminated soil from the
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Protected Area on the dike of the Storm Drain Collection Pond (SDCP)
(Paragraph 9)
The licensee had made discernable progress to develop a system to identify and maintain events / incidents significant with respect to decommissioning planning (Paragraph 10).
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l REPORT DETAILS i Persons Contacted Licensee Employees
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J. Casteen, Records Management Supervisor S. Fitzpatrick, Senior Specialist, Environmental and Chemistry (E&C)
- C Hinnant, Director of Site Operations !'
D. Hunt, System Engineer, Standby Gas Treatment-System (SGTS)
J. Johnson, Supervisor, E&C
- C. Robertson, Manager, Environmental and Radiation Control (E&RC)
- R. Smith, Manager, Radiation Control (RC)
- S. Watson, Manager, E&C
- G. Worley, Supervisor, RC Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personne Nuclear Regulatory Commission i
- P. Byron, Resident Inspector M. Janus, Resident Inspector R. Prevatte, Senior Resident Inspector
- Attended exit interview Acronyms and Initialisms used throughout this report are listed in the last paragrap . Organization (84750 and 86750)
Technical Specification (TS) 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 materia Both groups were organized'within the Environmental and Radiation Control (E&RC) Unit, under direction of the.E&RC Manager. Corporate reorganization had resulted in an increase in the E&RC Department's ,
total complement, from 108 to 120 positions, including.the addition of '
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six Radiation Protection Technicians, two Radiation Protection Specialists, and one each ' Training Specialist, Chemistry Specialist, Industrial Hygienist, and Radiation Protection Administrative
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o Supervisor. The E&C Manager, who reported directly to the E&RC Manager, directed a staff of thirty, including a technical aide, four senior specialists, three supervisors, and twenty-two technicians. At the time of this inspection, there was one vacancy, that of a technician who had recently resigned and whose position had not yet been filled. Also, as of early 1994, the E&C Manager and one of the Senior Specialists were i
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scheduled to 'take training for Senior Reactor Operation Certification, effectively vacating those positions for several months. In addition, a one of the E&C Supervisors was scheduled to begin an extended tour of duty with-the Institute of Nuclear Power Operations (INPO).
Furthermore, the Manager of Radiation Control responsible for radwaste -
handling and shipping was scheduled to transfer to corporate headquarters. The E&RC Manager was formulating his plans for the ;
replacement of these personnel with two principle goals in mind: '
maintaining the high standards of the E&RC Department; and giving other members of the department an opportunity for additional responsibilit The inspector concluded that the licensee's E&C and Radwaste Management ,
organizations and personnel therein were capable of effectively '
discharging their duties as related to chemistry / effluents and radioactive waste management and that TS requirements were satisfie No violations or deviations were identifie ,
3. Plant Water Chemistry (84750)
During the inspection, Brunswick Unit I was in cold shutdown, expected to return to service in late January, and Unit 2 was operating at :
one hundred percent power. Unit I had completed its eighth fuel cycle and Unit 2 was in its tenth fuel cycle. The next Unit 2 refueling outage was scheduled to begin in March 199 .
The inspector reviewed the plant chemistry and operational controls '
affecting plant water chemistry. TS 3.4.4 specifies that the concentration of chloride and the conductivity level in the Reactor Coolant System (RCS) be maintained below 0.50 parts per million (ppm)-
and 2.0 micro-mhos per centimeter (p mhos/cm), respectively. TS 3. specifies that the specific activity of the reactor coolant be limited to less than or equal to 0.2 microcuries/ gram (pCi/g) dose equivalent iodine (DEI).
These parameters are related to corrosion resistance and fuel integrit The chloride parameter is based on providing protection from halide stress corrosion. The conductivity parameter is based on reducing corrosion potential. The activity parameter is based on minimizing personnel radiation exposure during operation and maintenanc Pursuant to these requirements, the inspector reviewed daily tabular summaries which correlated reactor power output to chloride _ _
concentration, conductivity level, and specific activity of the reactor coolant for the period of October 1,1993'through November 30, 1993 for Unit 2. Typical values for chloride and conductivity were less than one part per billion (ppb) and less than 0.15 mhos/cm,respectivel Typical DEI values at steady-state conditions ranged from 1.45E-4 pCi/g to 7.55E-5 pCi/g. Unit I had no fuel in its reactor as work was being done on the reactor's shroud. Unit 2 had shown no ' evidence of leaking fuel during the current fuel cycl . _ _ _ _ _ .
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The inspector concluded that the Plant Water Chemistry was maintained t well within the TS requirement '
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No violations or deviations were identified. Hydrogen Water Chemistry (HWC) (84750)
The inspector reviewed the status of the licensee's HWC Program. The licensee planned to continue operating Unit 2 under HWC during the ,
remainder of Fuel Cycle 10, as referenced in Paragraph 16.c of !
Inspection Report (IR) 50-325,324/92-06. Although originally established to mitigate Intergranular Stress Corrosion Cracking (IGSCC) +
of the reactor coolant system, unexpectedly high dose rates during plant operation, especially in the piping of the reactor's recirculation system, had prompted the licensee to conduct a re-evaluation of the- ,
trade off between the program's benefits of reduced IGSCC versus the -
disadvantages of higher doses to plant personnel as additional '
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operational experience is gained. The Hydrogen Injection System for Unit 2 was operable at the time of this inspection, injecting twenty i standard cubic per minute (scfm) into the RCS. The licensee had
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initiated Plant Modification (PM)93-044 to increase the hydrogen ;
injection capacity on the Unit 1 system up to one hundred scf Installation of the PM was scheduled prior to Unit I startup (late January 1994). The Startup Ascension Plan would begin at that time and ,
it included testing of the HWC System up to twenty scfm. Upon satisfactory completion of the Ascension Plan, the Operations Department would be responsible for the routine operation of the plan Later, during a period when a minimal number of people were scheduled to be on +
site (probably a weekend or holiday) to minimize personnel dose, the 4 injection rate would be increased to between thirty to forty scfm and held there while the associated radiological effects were evaluate If the effects were found to be within expectations, this elevated rate -
would be continued until another period when a minimal number of people -!
were scheduled to be on site and the injection rate would be increased '
in a step-wise fashion, i.e., the injection rate would be increased and held at that level while the associated radiological effects were evaluated. This process would be continued until the design capacity of '
one hundred scfm was injected and evaluated. The process would be reversed, i.e., stepped down, to approximately forty scfm, where the plant was expected to operate in the future. This entire evolution was planned to be completed before beginning the next Unit 2 refueling outage, scheduled for late March 1994. The injection capacity of the HWC system of Unit 2 was scheduled to be similarly enhanced during the - l outage, via PM 93-045. Similar acceptance testing was envisioned but had not been finalized. The licensee planned to incorporate lessons -
learned from the Unit 1 evaluations while also accounting for two concurrently-operating unit During the current refueling outage of Unit 1, In-Vessel Visual Inspection (IVVI) identified two indications of cracking in the i reactor's shroud. One was located in the "H3" weld of the top guide support ring and was conservatively evaluated as a 360-degree
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circumferential flaw. The other was located on the exterior surface of the shroud in the Heat Affected Zone (HAZ) of the "H2" weld. These welds join the upper cylindrical shroud section to the slightly smaller diameter middle shroud section via attachment to the inside and outside of the top guide support ring, respectively. The predicted growth rate of the H3 weld was such that, while the cracking would technically remain within acceptable design limits, the licensee determined that a more prudent course of action would be to install mechanical clamps to
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ensure structural integrity of the core shroud at the H2 and H3 weld The clamps were designed to structurally link the upper shroud section, top guide support ring, and middle shroud section, thereby eliminating any reliance on the structural integrity of the H2 and H3 welds. They-were to be installed symmetrically around the shroud's exterior via through bolts, two above the H2 weld and two below the H3 weld, positioned such that there would be minimal impact to plant maintenanc The holes through the shroud to accommodate the through bolting was done by a technique known as Electro-Discharge Machiring (EDM). This process produced a swarf material, which was radioactive due to the activation products of the shroud material. The majority of the swarf was collected via an underwater vacuum and filter arrangement. The filters were configured into two trains, each with a ten-micron and one-micron filter in serie The filters were changed out on either pressure differential (which indicated that the filter was heavily loaded with swarf condensed particulate material) or dose rate (which could make disposal shipping difficult) limits established by the Radwaste Shipping Unit. Generally, the holes cut above the H2 welds caused the filters to be changed out due to differential pressure, while the holes cut below the H3 weld caused the filters to be changed out due to high dose rat At the time of the inspection, 417 filters had been placed in seven Radlock liners outside the power block and were awaiting shipping to the disposal facility in Barnwell, South Carolina. There had been a problem at the laboratory which was analyzing the filter material for characterization purposes prior to shipping, resulting in a delay in shipping of several days. (The licensee received the analysis on the morning of December 3, and planned to commence shipping the liners the following week.) The inspector went to the refueling deck to observe work in progress. All of the holes had been made in the sh oud and installation of the clamps had begun. About 120 filters were temporarily being stored in an aluminum " basket" in the equipment pool awaiting loading into liners for processing prior to shipping to the disposal facilit The process of loading the filters into a " transport box" underwater, lifting the box out of the water, allowing the filters ,
to drain for a short period of time (approximately ten minutes), and placing them into the shielded shipping liner on the Refueling Floor was explained to the inspector. The loaded liner was then turned over to the Radwaste Shipping Unit, which was responsible for storing it' safely while on site and preparing it for shipping to the disposal facilit Upon completion of the clamp installation, the licensee planned to vacuum the reactor to remove as much residual swarf as possibl '
Expectations were that an additional two to four liners of filters would be generated for disposa :
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In an effort to minimize crack propagation-in welds throughout the core shroud, the licensee planned to use HWC during the next fuel cycle for ;
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No violations or deviations were identified.
5. Confirmatory Measurements (84750) ,
10 CFR 20.201(b) requires the licensee to perform surveys as necessary to evaluate the extent of radiation hazards. In an effort to evaluate the licensee's analytical capabilities, the licensee was provided spiked liquid samples for analysis pursuant to the NRC Confirmatory ,
Measurements Program. Specifically, the licensee was requested to :
analyze samples of beta-emitting radionuclides containing tritium (H-3),
iron-55, and strontium-90. The licensee reported the analytical results 1 of this batch on September 3,1993 via the corporate Energy and Environmental (E&E) Center, located at the Shearon Harris Nuclear Power Plant (SHNPP). As indicated in Attachment 1, the licensee's analytical results were in agreement with the prepared concentrations for the three o isotopes identified. Attachment 2 provides the criteria for assessing the agreement between the licensee's analytical results and the prepared concentration The inspector concluded that the licensee maintained a good Counting Room radiochemical analysis program for the detection of beta-emitting radionuclide No violations or deviations were identified.
6. Post Accident Sampling System (PASS) (84750)
NUREG-0737 requires that the licensee be able to obtain a sample of the reactor coolant and containment atmosphere. Furthermore, the sample must be promptly obtained and analyzed (within three hours total) under -
accident conditions without incurring a radiation exposure to any individual in excess of 3 and 18 3/4 rem to the whole body or extremities, respectively. Furthermore, TS 6.8.3.c requires that a program shall be established, implemented, and maintained which "will ensure the capability to obtain and analyze reactor coolant, radioactive i iodines and particulates in plant gaseous effluents, and containment i atmosphere samples under accident conditions." The program shall include: training of personnel; procedures for sampling and analysis; and provisions for maintenance of-equipmen !
l Prior to the startup of Unit 2, the licensee had completed PM 92-114 to l replace the PASS small volume sample valve (2-RXS-CV-616) and associated I actuator and 3-way solenoid valve with a 4-way air-operated piston-type i
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sample valve and associated two-piston pneumatic actuator and 4-way i solenoid valve. (Refer to Paragraph 3 of IR 50-325, 324/93-09.)
Discussions with the cognizant licensee Senior Specialist determined !
that initial problems in obtaining the sample of such a small volume !
were encountered. Various delivery techniques were tried until a consistent sample volume was obtained and verified. The successful ,
technique was then incorporated into the PASS sampling procedur The PM for the Unit 1 PASS, PM 92-113, had been coinpleted as far as the installation of the replacement valve. However,. operability testing could not be done until a few weeks after startup of the uni ,
The Radwaste Shipping Supervisor had written a Plant Emergency Procedure (PEP) for the transport of a post-accident sample to an off-site facility for analysis, should that action become necessary. The inspector reviewed a draft copy of the PEP and determined that it was-technically well-written. The objectives and individual responsibilities of the decision-making personnel as well as the circumstances under which implementation of the procedure could be evoked were clearly define The inspector concluded that the licensee was taking proactive measures ~!
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to upgrade the PASS and to prepare for an emergency shipment of a potentially highly radioactive post-accident sampl No violations or deviations were identified. Standby Gas Treatment System (SGTS) Inleakage Status (84750)
During a Dioctyl Phthalate (D0P) test and inspection of the SGTS-at i another Boiling Water Reactor (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 releas As referenced in IR 50-325, 324/92-25 and IR 50-325, 324/93-09, the licensee had initiated tests to evaluate current / potential inleakage problems with the system. Some indication of inleakage was. expected because the shaft seals were originally designed to be leak-limiting, ';
rather than leak-proof. Furthermore, a visuel inspection by the ,
licensee determined that the seals had harde1ed over time. Qualified replacement seals had been ordered and were >n site and the licensee had -
initiated work orders to install the new seats. The seals on the two Unit I sy. stem trains were scheduled to be installed during the week following this inspection by work orders WR/JO 92AYAY1 and 92AYAXI. The ;
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seals of the two Unit 2 system trains were scheduled to be installed during the next Unit 2 refueling outage in March 199 ;
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The inspector concluded that the licensee was taking a proactive position in the resolution of this issu No violations or deviations were identifie = Solid Radioactive Waste Management-(86750) I 10 CFR 71.5 requires that licensees who transport licensed material outside the confines of its plant or other place of use, or who deliver licensed material to a carrier for transport, shall comply with the ('
applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 through 18 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 characteristics requirements of 10 CFR 61.56. It further establishes specific requirements for conducting a quality control program and for maintaining a manifest tracking system for all shipment The inspector reviewed the licensees's solid waste management program for wastes generated from BNP operations. The review included the following: adequacy of implementing procedures to classify and characterize the wastes; preparation of the manifest and marking of packages; overall performance of the process control and quality control programs; and the adequacy of required records, reports, and notification Observation of a Shipment
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The inspector observed Shipment No.93-290, a High Integrity Container (HIC) containing dewatered bead resin destined for disposal at the Low Level Radioactive Waste Disposal Facility at Barnwell, South Carolina. The inspector reviewed the records of the shipment prior to its leaving the site. The radiation and L contamination survey results were within the limits specified for the mode of transport and shipment classification. The shipping manifest examined was consistent with the D0T requirements, including the 24-hour emergency telephone number. The inspector also surveyed the shipment before it left the site to verify the licensee's survey and determined that it was accurat Based on these observations, the inspector concluded that the shipment was handled competently and was properly documented, Radioactive Materials Shipment Documentation Packages Shipment of radioactive materials was the responsibility of the Radioactive Waste Group, which prepared all shipping documents and procured the necessary disposal containers and shipping cask The inspector reviewed two shipping documentation packages for
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radioactive materials shipments made since the last inspection, including Shipment Nos.93-278, a low Specific Activity (LSA) e shipment (specifically, a Hic of dewatered bead resin destined for disposal at the Low Level Radioactive Waste Disposal Facility at
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Barnwell, South Carolina) and 93-255, contaminated camera equipment destined for another nuclear plant site. -Generally, the documentation packages were thorough and included shipment ,
information such as unique shipment and shipping container ;
numbers, waste content and volume, total activity, analytical summary and breakdown of isotopes with a half-life greater than five years, a 24-hour emergency telephone number, emergency response information sheets, etc. The radiation and contamination survey results were within the limits specified by 49 CFR and the ;
shipping documents were being maintained as required.
However, during the review of the documentation for Shipment No.93-255, the inspector noted that on the content description manganese-54 was listed twice, once as "Mn-54" and once as i
"MN-54." The program used by the licensee.to list the isotopic contents of the shipment treated these two entries as different isotopes due to the upper and lower case "n" used in the isotopic designation. The program then double-counted the activity in calculating the total shipment activity, resulting in a conservative summation, i.e., a greater activity was listed in the shipping documentation than was actually transported. When this observation was brought to the attention of the licensee, prompt action was taken to review the documentation of other shipments made before and after this.one for similar double listings. .None were foun Furthermore, the licensee determined that the double-listing occurred due to using the library of one part of the program which was normally associated with a different part of the program. Through a bit of experimentation, the licensee learned that the technique of using this combination of library and different program part resulted in a double listing of all isotopes with more than one letter in its designation. The licensee also initiated Adverse Condition Report (ACR) 93B90292 to investigate the finding. The licensee contacted the vendor of the !
computer program used to generate the shipping documentation and was informed by the vendor that it was aware of the situation and planned to update the program in the future. To assure that this situation did not recur, all shipping personnel responsible for preparing shipping documentation were informed of the development .
and instructed to be especially alert for it when preparing or
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reviewing the documeniction. Also, the shipping departments at the other two CP&L nuclear sites were informed of the above-referenced events. From a telephone conversation with licensee personnel the week following the inspection, it was learned that-the vendor had sent a notice to all: users of the referenced program explaining the problem and would make appropriate ,
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The inspector concluded that the shipping packages were properly documented, with the noted exception, and that the licensee had taken appropriate actions to assure that the referenced computer t problem was resolved expeditiousl ' Record Retention TS 6.10.1.f requires that records of radioactive materials '
shipments be retained by the licensee "for at least five years."
The inspector went to the licensee's Document Control Vault and requested the shipping records for the randomly-selected years of 1989 and 1991. The documents, stored on microfiche, were produced ;
for the inspector's review in a timely manner. The inspector randomly chose the following seven shipments to assess the licensee's compliance with the TSs: 89-01, 89-11,91-094, 91-107,91-108, 91-109, and 91-110. The records were complete, containing the same elements as the shipping packages of subparagraph b, abov The inspector concluded that the licensee' had good programs' in place for the handling and shipping of raoioactive material and that they were ;
effectively implemented by a competent, dedicated staf ,
No violations or deviations were identifie . Status of Contaminated Soil Transfer (84750)
As referenced in Paragraph 9 of IR 50-325, 324/93-36, the licensee had '
continued to transfer slightly contaminated soil from inside the Protected Area to inside a fenced and posted Radioactive Materials Area on its property for use as stabilization material on the inside slope of !
the dike surrounding the Storm Drain Collection Pond (SDCP) The source I of the material was the accumulation of sand / soil for approximately th last dozen years in the plant's drainage basins as well as additional i soil resulting from the lowering of the grade of certain areas within ;
the Protected Are The inspector reviewed the progress of the transfer. The licensee continued to work to Environmental and Radiation Procedure 0-E&RC-0508,
" Transfer of Sand / Soil to the Storm Drain Collection Pond," approved .
March 25, 1993, which provided guidance for and control of the transfe !
Through November 30, 1993, the licensee had transferred approximately )
14700 cubic feet of material containing approximately 6.2 millicurie ,
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Under this program additional material would be transferred as the need arose, to a maximum of five curie The inspector concluded that the licensee's program.for soil transfer was adequate and that its implementation was satisfactor No violations or deviations were identifie l
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- 10 1 Decommissioning Planning Records (84750) .j 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 j areas where radioactive materials are used and/or stored and of locations of possible inaccessible contamination such as buried pipes i which may be subject to contamination."
During the current inspection, the inspector discussed the issue with ;
the Records Management' Supervisor to determine the status of the o licensee's program. Although not yet fully implemented, progress was :
evident since the last inspection in this area. (Refer to Paragraph 11 ~
of IR 50-325, 324/93-36.) The licensee had modified its data base to provide a field to identify records deemed necessary for decommissioning planning purposes. For drawings, a similar_ effort was being made via an i Information Resource Request (IRR) to enhance the Nuclear Revision
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Control System (NRCS) to provide a field for identifying pertinent-drawings. In addition, technical support documents and ad hoc reports !
had been reviewed by E&RC'for applicability. Also, the procedures for a new records management program had been developed to identify future ;
documents relevant to decommissioning planning. They were in the !
comment / review cycle at the time of the inspection. Furthermore, Engineering Work Request (EWR) 12970 had been written asking Engineering !
to determine the types of drawings which may be required for l decommissioning. (The EWR is due on March 31,1994.) (Previously, :
t Records Management had written EWR 12833 with a similar reques However, Engineering determined that the request was ambiguous and that i clarification was needed.) To assure program compatibility among the three CP&L nuclear sites, several meetings between plant Records j Management personnel had taken place during the past several month l
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The licensee planned to modify the Records Management System and NRCS such that there would be special entries to identify all documents and i drawings deemed appropriate by E&RC and Technical Suppor !
Although some parts of the program had been implemented, complete !'
implementation was not expected until the spring of 199 The inspector concluded that the licensee had made discernable progress (
in the implementation of the program to identify records necessary for l decommissioning plannin No violations or deviuions were identifie :
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.I 11. Exit Interview ;
The inspection scope and results were summarized on December 3, 1993, l with those persons indicated in Paragraph 1. The inspector described i the areas inspected and discussed the inspection results, including
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i 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 proprietar Dissenting comments were not received from the license ;
i 12. Acronyms and Initialisms :
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ACR - Adverse Condition Report ;
BNP - Brunswick Nuclear Project -
BWR - Boiling Water Reactor i CFR - Code of Federal Regulations j Ci - curie !
cm - centimeter !
CP&L - Carolina Power and Light ;
DEI - Dose Equivalent Iodine !
DOP - Dioctyl Phthalate :
DOT - Department of Transportation ;
E&C - Environmental and Chemistry :
E&E - Energy and Environmental ' ;
E&RC - Environmental and Radiation Control !
EDM - Electro-Discharge Machining ;
- Engineering Work Request
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EWR g - gram HAZ - Heat Affected Zone HEPA - High Efficiency Particulate Air HIC - High Integrity Container ;
HWC - Hydrogen Water Chemistry i IGSCC - Intergranular Stress Corrosion Cracking INP0 - Institute of Nuciear Power Operations -
IR - Inspection Report :
IRR - Information Resource Request I IVVI - In-Vessel Visual Inspection ;
LSA - Low Specific Activity '
pCi - micro-Curie (1.0E-6 Ci)
pmho - micro-mho (1.0E-6 mho) '
ml - milli-liter N number i
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NRC - Nuclear Regulatory Commission NRCS - Nuclear Revision Control System l PASS - Post Accident Sampling System- ;
pCi - pico-Curie (I.0E-12 C1) !
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PEP - Plant Emergency Procedure PM - Plant Modification i ppb - parts per billion i ppm - parts per million ;
RC - Radiation Control I RCS - Reactor Coolant System i
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12 i scfm - standard cubic feet per minute i SDCP - Storm Drain Collection Pond l SGTS - Standby Gas Treatment System .;
SHNPP - Shearon Harris Nuclear Power Plant i TS - Technical Specification [
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L t L l L i ATTACHMENT 1 1
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COMPARISON OF NRC AND CP&L ANALYTICAL RESULTS .
REPORTED SEPTEMBER 3,1993 i o ,
l Type of Sample: Unknown NRC Spikes 1 y Units: Ci/ml ]
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?- Radio- Licensee's NRC- Reso- .
Compar- l l- nuclide Value (uCi/ml) Value (uCi/ml) lution Ratio ison ;
i l H-3 1.30 E-4 (1.29 +/- 0.06)E-4 22 1.01 Agree !
l Fe-55 1.35 E-5 (1.23 +/- 0.06)E-5 21 1.10 Agree !
Sr-90 2.30 E-5 (2.33 +/- 0.12)E-5 19 0.99 Agree l
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ATTACHMENT 2 ,
CRITERIA FOR COMPARISONS OF ANALYTICAL MEASUREMENTS *
l This attachment provides criteria for the comparison of results of analytical radioactivity measurements. These criteria are based on empirical relationships which combine prior experience in comparing radioactivity emission, and the accuracy needs of this progra In these criteria, the " Comparison Ratio Limits"' denoting agreement or' disagreement '
between licensee and NRC results are variable. This variability is a function of the ratio of the NRC's analytical value relative to its associated statistical and ;
analytical uncertainty, referred to in this program as " Resolution".2
'
For comparison purposes, a ratio between the licensee's analytical value and the NRC's analytical value is computed for each radionuclide present in a given sampl ,
,
The computed ratios are then evaluated for agreement of disagreement bases on r
" Resolution." The corresponding values for " Resolution" and the "ComparisonL Ratio Limits" are listed in the Table below. Ratio values which are either above or below the " Comparison Ratio Limits" are considered to be in disagreement, while ratio values within or encompassed by the " Comparison Ratio Limits" are considered to be in agreemen l TABLE :
NRC Confirmatory Measurements Acceptance Criteria Resolution vs. Comparison Ratio Limits ,
Comparison Ratio Limits Resolution for Agreement
<4 0.4 - .5 - .6 - 1.66 !
16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25 '
> 200 0.85 - 1.18
'Comparisan Ratio - Licensee Value NRC Reference Value
Resolution - NRC Reference Value Associated Uncertainty
_ _ . . _