ML20140D178
| ML20140D178 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/12/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20140D165 | List: |
| References | |
| 50-324-97-05, 50-324-97-5, 50-325-97-05, 50-325-97-5, NUDOCS 9706100280 | |
| Download: ML20140D178 (31) | |
See also: IR 05000324/1997005
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION II ,
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Docket Nos: 50 325, 50 324
' Report No: 50 325/97 05, 50 324/97-05 f
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Licensee: Carolina Power & Light (CP&L)
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Facility: Brunswick Steam Electric Plant, Units 1 & 2 !
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Location: 8470 River Road SE -
Southport NC 28461
Dates: March 2 April 12, 1997
Inspectors: C. Patterson, Senior Resident Inspector
E. Brown, Resident Inspector
W. Rankin, Regional ' Inspector (Section R1)
Approved by: M. Shymlock, Chief, Projects Branch 4 j
Division of Reactor Projects- !
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Enclosure 2
9706100280 970512 "
PDR ADOCK 05000324
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, EXECUTIVE SUMMARY
Brunswick Steam Electric Plant, Units 1 & 2
NRC Inspection Report 50-325/97-05, 50 324/97-05
This integrated inspection included aspects of licensee operations,
engineering,' maintenance, and plant support. The report covers a 6 week ,
period of resident inspection: in addition, it includes the results of a ~
radiological protection and chemistry controls by a regional inspector.
l Ooerations
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The present method of conducting an operation shift crew post turnover '
meeting was not effective to make the operators fully aware of plant
- changes and problems prior to assuming the shift responsibilities. .
(Section 01.1). The licensee was responsive to this concern and
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initiated changes to the shift turnover process for in coming crews that l
had been off site for several days.
The licensee recalibrated the unit 1 feedwater flow instrumentation
resulting in a power decrease due to conflicting test data.
(Section 08.2). The instruments were recalibrated to the more
conservative of ultrasonic flow test data and feed flow tracer data.
Maintenance
A violation was identified for failure to properly perform a
surveillance test for the core spray sparger leak detector system.
(Section M3.1). The normal range was defined in the procedure.
However, the normal range had actually changed in the plant.
An inspection followup item was opened to review why the core spray
sparger leak detection system normal differential pressure had shifted.
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(Section M3.1). This will be accomplished during the next refueling
outage. The licensee's operability assessment concluded that the
instrumentation would still be functional during a line break. ,
Good coverage of maintenance activities by maintenance line supervision
and the health physics technician was observed during RCIC system
maintenance activities. (Section M1.4). Adequate supervisory oversight
and procedural use was observed during monthly diesel testing.
Maintenance activities with regards to securing wheeled equiament has
improved. (Section M2.1). Further attention is needed in t1e area of
foreign material exclusion around the spent fuel pool. '
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Enoineerina
A violation was identified for failure to take corrective action once
notified of an error in the rod withdrawal accident analysis. (Section
E2.1). A condition report was not initiated for this issue, that was
subsequently determined reportable, until questioned by the inspector.
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An unresolved item was identified covering issuance of a Notification of
Enforcement Discretion concerning deletion of certain response time
testing requirements. (Section E3.1)
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L Plant Sucoort i
Chemistry parameters were maintained well within TS and licensee
administrative limits. The licensee's water chemistry control program
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for monitoring water quality at specified surveillance frequencies had
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been implemented in accordance with the licensee's TS requirements.
(Section R1.1)
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The licensee had maintained an effective program to monitor and control
liquid and gaseous radioactive effluents and thereby limit doses to
members of the public to a small percentage of regulatory limits.
(Section R1.2)
The release of radioactive material to the environment from liquid and
gaseous effluents for 1995 and 1996 was a small fraction of the
10 CFR 20, Appendix B and 10 CFR 50, Appendix I limits. (Section R1.2)
The projected offsite dose commitments which resulted from plant liquid
and gaseous effluents were well within limits specified in the TSs and ,
the Offsite Dose Calculation Manual (0DCM). (Section R1.2) I
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The results of planned licensee activities to reduce tritium in the
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stabilization pond will be reviewed in the future and tracked as an
inspector followup item. (Section R1.2)
Radwaste minimization efforts were successfully reducing radwaste volume ,
with a .significant reduction in the rate of radwaste generation evident )
from 1996 to 1997 year to date. (Section R1.2) j
The radiological controls program was being effectively implemented with
generally good occupational exposure controls observed during normal
plant operating conditions. (Section R1.3)
Good radiological control performance was apparent in specific work
activities observed by the inspectors. (Section R1.3)
The licensee was effectively controlling operational site exposures to
low levels during the period of inspection although sitewide dose
performance for 1996, at 702 person rem, remained relatively high.
(Section R1.3)
An unresolved Item was identified concerning the movement valve to a
radioactive material storage area. (Section R1.3)
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The licensee had implemented an effective program for packaging,
preparation, and transport of radioactive material in accordance with
regulatory requirements. (Section R1.4)
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An unresolved item was identified to review licensee documentation to
demonstrate compliance with 10 CFR Part 71.137 audit requirements. .
(Section R1.4)
~ An inspector followup item was opened for an audit finding concerning
plant access searches. (Section S1.1) <
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Report Details
Summary of Plant Status '
Unit 1 operated continuously during this period without any significant
problems. A power adjustment was )erformed due to calibration of
feedwater flow instrumentation. T11s is discussed in paragraph 08.2.
At the end of the inspection period the unit had been on line 156 days.
On November 1, 1996, the NRC approved amendments to the Brunswick
operating licensee for a five percent increase in maximum licensed power
level. Prior to operation at u) rated )ower levels on Unit 1 the
licensee identified errors in t1eir su3mittals. The licensee committed
to hold power at the previous maximum licensed aower level until all
issues were resolved. On March 18,1997, the N1C completed its review '
of these problems and in a letter to the licensee did not object to
operation of Brunswick to the uprate licensed maximum power. Power
increase to the maximum power was contingent upon scheduling and
completion of power ascension tests. At the end of this report period,
testing had not been completed. Unit 1 remained at 95% power.
Unit 2 operated continuously during this period without any significant
problems. At the end of the inspection period, the unit had been on-
line 211 days.
The mechanical vacuum pumps remained tagged out on both units due to
concern about control room dose in the event of a Rod Drop Accident.
The licensee, in a letter to the NRC dated February 13, 1997, committed
to upgrade the mechanical vacuum pump trip function to implement a
vacuum pump trip from the main steam line radiation monitor prior to the
next startup.
Seven of eight Justification for Continued Operation (JCO) in the
Environment Qualification (EQ) of equipment area remain open for both
units. The following provides the status of the EQ JCOs and associated
Engineering Service Requests (ESRs):
1) ESR 96 00425, Evaluation of EQ sealants was considered closed by
the licensee.
2) ESR 96 00503, Associated Circuit EQ was scheduled for completion
May 31, 1997.
3) ESR 96 00426. Evaluation Quality class and EQ classification of
Post Accident Sample System valves was scheduled for completion
June 6, 1997.
4) ESR 96 00501, Motor Control Center (MCC) EQ was scheduled for
completion June 6,1997.
5) ESR 96-00625, EQ Type JC0 for EQ Fuses Without a Qualification
Data Package (QDP) was scheduled for completion June 6,1997.
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6) ESR 96 00627, ODP for Marthon 300 Terminal Blocks was scheduled 4
for completion December 31, 1997.
7) ESR 97 00087, EQ Type JC0 for Improperly Configured Conduit Seal -
was scheduled to be completed June 30, 1997.
8) ESR 97 00229. JC0 for GE CR 151 B Terminal Blocks was scheduled to
be completed July 15, 1997.
In addition, a JC0 and an Operations Standing Instruction SI 97 016,
remains in effect 3roviding guidance and allowed out of service time for !
the three control auilding air conditioning units. During a Safety
System Functional Inspection conducted in May June 1996, it was
identified that the units were incorrectly downgraded from safety :
related or Q list to non safety related. ESR 96 00366. Evaluation of
Using Existing Control Room Air Conditioners, provided a JC0 evaluation
until the issue was resolved. The issue remains open and the licensee
committed in their February 15, 1997, letter to resolve all open issues :
by the completion of the Unit I refueling outage 12, scheduled to begin ,
in the second quarter of 1998.
In summary, both units operated continuously during this report period. !
However, there are seven outstanding JCOs in the EQ area and one JC0 for
the non-Q control building air-conditioning units. Mechanical vacuum
pumps due to concerns related to Rod Drop Accident analysis remain
tagged out.
I. Doerations
02 Operational Status of Facilities and Equipment
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02.1 Shift Turnover Meetinas
a. Insoection Scope (71707)
The inspector reviewed the operation crew shift turnover meeting and
discussion held on March 4, 1997.
b. Observations and Findinos
On March 4, 1997, the inspector observed at 7:10 a.m. the crew (that had
just assumed the shift responsibilities) conduct a turnover meeting in
the control room, The shift turnover meetings are conducted different
from what the inspector had encountered at other facilities. Although
called a shift turnover meeting, the meeting was a post turnover '
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meeting. Each operator conducted a one on one turnover and assumed the
shift. The off going crew left the control room and left the site.
Each unit SR0 gave a status of the unit, etc. The crew (assigned to the
day shift) had been off several days prior to the meeting and was off -
work when the recirculation aump transients occurred on March 1,1997.
The crew stated that the pro)lems had occurred but that someone later in
the shift would give them the details.
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The inspector noted that the crew did not have a good pers)ective of
plant problems which had occurred since being off work. T1ese problems 1
were not discussed with the crew prior to them assuming the watch. The l
inspector discussed this concern with lant management. Also, the j
inspector discussed that at the other icensees' facilities shift ,
turnover was conducted in a more conventional way with a turnover l
meeting prior to assuming the shift responsibilities. l
In response to this issue, the licensee implemented a pre shift turnover
meeting for the on coming crews that had been off work for several
shifts. As the crews are on 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts, the licensee concluded that
the last 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> off shift could quickly be reviewed for plant changes j
and a pre shift turnover was not necessary. i
The inspector attended the pre shift turnover meeting on April 8, 1997.
The meeting was conducted by the off going shift supervisor. Changes
for the several days the shift was off work were reviewed. ;
c. Conclusions i
The inspector. concluded that the present method of conducting a post '
turnover was not effective to make operators fully aware of plant
changes and problems prior to assuming the shift responsibilities. The
licensee was responsive to this concern and initiated changes to the i
shift turnover process for on coming crews that had been off site for ;
several days. l
08 Miscellaneous Operations Issues (92901) f
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08.1 (Closed) LER 50 324/96 04: Jet Pump Surveillance Not Performed Prior to
Exceeding 25% Reactor Power. l
This licensee event report (LER) reported the events surrounding the !
discovery that the jet pump surveillance was not performed prior to ,
exceeding 25% reactor power. During power ascension from 153 to 30%, (
the licensee failed to perform Periodic Test OPT 13.1 Reactor ;
Recirculation Jet Pump Operability. Satisfactory performance of OPT.
13.1 would have satisfied the surveillance requirements stated in TS j
4.4.1.2.1. The licensee, upon recognizing the failure, reduced power -
below 25% and entered the Limiting Condition for Operation (LCO) for TS '
3.4.1.2. The jet pump surveillance was satisfactorily performed and the ;
LCO exited.
The inspector reviewed the LER, associated condition report, and l
corrective action program action items. TS 4.0.4 requires that entry ;
into an operational condition or other specified applicable state shall
not be made unless the surveillance requirements associated with the LC0
have been performed within the applicable surveillance interval or as
otherwise specified. The inspector concluded that the failure to
perform surveillance testing to satisfy jet pump operability
requirements prior to exceeding 25% rated thermal power was a violation
of TS 4.0.4. This licensee identified and corrected violation is being
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treated as a Non Cited Violation, consistent with section VII.B.1 of the !
NRC Enforcement Policy and is identified as NCV 50 324/97 05 01, Missed ,
Jet Pump Surveillances. Based on satisfactory completion of the '
licensee corrective actions and issuance of the above NCV, this item is
closed. j
08.2 (00en) LER 50-324/96 03 01: Operation in Excess of Maximum Power Level !
Specified in Operating License.
In this LER the licensee committed to test and calibrate the reactor
feedwater flow venturis by March 31, 1997. The licensee stated
additional time was needed to complete this action and revised the ;
commitment date to May-30, 1997.
On April 2,1997, the licensee initiated CR 97 1293 titled
Nonconservative Feedwater Flow Indication. Ultrasonic flow testing on i
the feedwater water flow venturis revealed that the plant indicated i
feedwater flow for Unit I was nonconservative by about 1.6 percent.
Feedwater flow inputs into the reactor power level calculation. If the
new data was accurate, actual reactor power was 2479 MW thermal when
indicated power was 2436 MW thermal. Data for Unit 2 indicated the
valves were conservative. This data was in conflict with feedwater flow
tracer testing performed in 1994. Present steam plant data supported i
that the latest data was correct. However, questions remained as to why l
the difference. l
The licensee took action to reduce reactor power by 43 MW thermal (93%
power), and controlled the APRM gain adjustment factors and thermal
limits equal to 0.98.
On April 7,1997, the licensee recalibrated the Unit 1 feedwater flow
transmitters with new scaling factors which the licensee considers
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conservation. Unit 1 power was increased from 93% to 95% power. Power
increase to 100% was contingent upon completion of the power ascension
tests associated with the recently NRC approved increase in maximum
thermal power.
This LER will remain open pending completion of the commitment and
further NRC review.
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08.3 (Ocen) URI 50 325(324)/97-02 02: Recirculation Pump Transients. !
The inspector reviewed the licensee's root cause report for CR 97-00926 j
and CR 97-00923 concerning work in the switchyard on power circuit i
breaker, PCB 31A. Following maintenance the breaker was closed but a l
grounding strap had been left installed. This caused the breaker to
immediately open and a trip of the 2B recirculation motor generator set.
The licensee formed an event review team to assess the problem. The
licensee determined that the cause was due to poor worker practice, .
improper verification techniques, and insufficient administrative
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controls for maintaining status and accountability of materials. ,
Corrective action included personnel disciplinary action, training on '
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lessons learned, development of a ground tagging program, and general
review of transmission department work activities.
The inspector reviewed the licensee's event assessment team report and
concluded it was thorough. The inspector inspected the switchyard
around the PCB 31A breaker on March 5, 1997. There was no evidence of
any physical damage in the switchyard. This event was caused by
additional work outside the original job scope to remove a rag stuck in
the switch mechanism. The rag could not be easily removed. Two ground
straps were installed to allow removal of the rag. Only one ground
strap was removed and the procedure controls used initially were not !
followed. The procedures used were Transmission Services 3rocedures and 1
not governed by the plant operating requirements. Althoug1 this event )
occurred on the owner controlled property the same problem could have !
occurred off-site. l
Additionally, the inspector held discussions with the licensee regarding
the runbacks. Additional questions remain and this will remain open l
pending resolution of the questions. 1
II. Maintenance
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M1 Conduct of Maintenance j
M1.1 RHR Time Delay Relay Calibration
a. Inspection Scope (61726)
The inspector observed the performance of Maintenance Surveillance Test
Procedure IMST RHR28R, Time Delay Relays Channel Calibration.
b. Observations and Findinns
On March 5, 1997, the inspector observed the performance of IMST-RHR28R
for loop "A". This surveillance test performs calibrations of the time
delay relays associated with the 1 E11 F007A, Residual Heat Removal
(RHR) Minimum Flow Valve, 1-E11 F017A, LPCI Outboard Injection Valve. l
and 1 E11 F0048A, RHR Heat Exchanger IA Bypass Valve. Successful l
completion of the test partially satisfied the TS 4.3.3.2 requirement to '
calibrate the time delay relays for the RHR system.
The inspector verified that the required administrative approvals and
equipment tagouts were performed prior to beginning the testing. All
test instrumentation was verified to be within the current calibration
cycle. The test procedure was referred to at each step and the
inspector observed good procedural use, self-checking, and independent
verification. The inspector reviewed the test data and verified that
the values recorded were accurate and complete.
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Hl.2 Diesel Generator Monthly
a. Insoection Scooe (61726)
The inspector observed the performance of the monthly load test for
diesel generator (DG) 2.
b. Ebservations and Findinas
On March 31, 1997, the inspector observed the performance of Periodic
Test OPT-12.28, No. 2 Diesel Generator Monthly Load Test. OPT 12 2B was
performed to satisfy TS requirements 3.8.1.1.b and 4.8.1.1.2.a. The
test verified full level in the engine mounted and four day fuel tanks,
the diesel started and accelerated to rated speed in 10 seconds, the
generator could be successfully loaded and run for at least 15 minutes,
and the DG was properly aligned to provide power to the associated
emergency bus.
During the performance and review of the test the inspector observed
that testing was accomplished by qualified personnel, procedural
precautions and limitations were followed, and acceptance criteria met.
Inspector review determined that the procedure conformed to the TS
requirements. -The inspector independently verified selected parameters
during the surveillance
the required frequency. The performance and thatadequate
inspector observed the test supervisory
was completed at
oversight and procedure use.
H1.3. RCIC Maintenance Activities '
a. Inspection Scooe (62707)
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The inspector observed several maintenance activities during the Unit 1
Reactor Core Isolation Cooling (RCIC) System Outage.
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b. Observations and Findinas
On March 19, 1997, the inspector observed the installacion of
environmentally qualified (EQ) seals and mechanical valve lube
inspection on the RCIC system on Unit 1. The EQ seal installation was
performed to address EQ concerns with the position of the seal for
selected safety related instrumentation. During seal replacement on the
IE51 PSH N012A, RCIC Turbine Exhaust Diaphragm High Pressure Switch, the
ins actor observed adequate communication and coordination between the
war (ers, procedures had been properly approved and in use. The
inspector noted a good practice in the inclusion of relevant
administrative procedures in the work packages. Inspector observations
of mechanical valve lubrication inspections identified no concerns or
deficiencies.
The inspector verified that all applicable limiting conditions for
operation were appropriately entered and exited and that operability
testing after the EQ seal installation was completed satisfactorily.
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In addition the inspector noted good coverage of the activities by line 1
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supervision and the health physics technician.
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l M1.4 Maintenance Conclusions
i Good coverage of maintenance activities by maintenance line supervision
and the health physics. technician was observed during RCIC system
j maintenance activities. Adequate supervisory oversight and procedural
i use was observed during monthly diesel testing.
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M2 Maintenance and Material Condition of Facilities and Equipment
M2.1 Maintenance Practices
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- a. Insoection Scone (62707)
The inspector performed observations of maintenance practices during
!- routine tours on April 8 9, 1997.
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- b. Observations and Findinas
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- During a routine tour of the Unit I reactor building on April 8, the 1
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inspector discovered a large cart of . scaffolding material on the 20 foot )
elevation without a wheel clamp. The lack of a clama could have allowed l
. the cart to roll and potentially impact nearby High )ressure Coolant
! Injection, Standby Gas Treatment, or RHR piping. The inspector notified
licensee personnel and a clamp was promptly applied.
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During a routine plant tour of the Unit I reactor building on April 9,
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the inspector discovered a clear plastic bag containing yellow
decontamination towels. This clear plastic bag was located less than 5
feet from the spent fuel pool. The clear translucent material would not
have been readily visible should it have fallen in the spent fuel pool.
The inspector promptly notified the control room and the bag was removed
from the floor.
Despite the discovery of one wheeled cart the inspector observed that
overall licensee performance with regards to the securing of wheeled
carts has improved. The licensee had recently improved the marking and
signs on the refuel floor to raise the level o c awareness with regards
to foreign material exclusion. The clear plas'ic bag left near the
spent fuel pool demonstrates that further attenPn is needed in this
area,
c. Conclusions
Maintenance activities with regards to securing wheeled equipment has ;
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improved. Further attention is needed in the area of foreign material
exclusion around the spent fuel pool.
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H3 Maintenance Procedures and Documentation
H3.1 Core Soray Soarcer Channel Calibration Procedure
a. Inspection Scone (61726)
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The inspector reviewed the actions associated with an abnormal ;
differential pressure reading on the Unit 1 Core Spray Sparger Break l
Detector.
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b. Observations and Findinas
On March 9,1997, an auxiliary operator was verifying instrumentation
indications and observed that the reading displayed for 1 F21 POS-N004A,
Core Spray Line Break Indicator, was not within specifications. This l
pressure switch functions to detect a break in the core spray (CS)
piping' located between the vessel and the shroud. The differential
pressure (dP) sensor measures the pressure across the core.
The inspector reviewed the associated instrumentation, Engineering
Service Requests (ESR) 95 238 and 97 181, CR 97 1053, and LER 50 325/
97 02, Core Spray Header Differential Pressure Instrumentation
Inoperable. In LER 97 02, the licensee stated that the safety
significance was minimal since an actual break in the core spray line
would have actuated the alarm. Immediate corrective actions included
recalibration of the 1 E21 PDS N004A which confirmed that the pressure
sensor was within tolerances. Additional action included backfilling
both sensing lines with no change in the readings. After completion of
the review of the existing documentation and discussions with the
licensee the cause for the abnormal indication has not been definitively
determined. The licensee surmises that the dP may have been affected by
voiding of the sparger nozzles. The CS dP nozzles may be empty or full
depending on local hydraulic / thermodynamic conditions.
Pending completion of the NRC's review of the licensee's corrective
actions and further investigation of the problem, this item will be
tracked as Inspector Follow up Item IFI 50-325/97 05-02, Abnormal CS
Sparger Break Detector Indication.
TS surveillance operability requirement 4.5.3.1.c.2 required the
performance of a channel calibration for dP instrumentation every three
months and verification that the setpoint is 5 i 1.5 psid greater than
normal dP. The setpoint was set at +31 i 7 inches of water back in 1985
was based on a normal value of 108 inches of water. Upon determining
that the actual normal value was 154 inches of water, the licensee
concluded that the dP instrument had not been in compliance with TS
surveillance requirements. The 154 inches of water value was
determined as recorded in the system engineer's walkdown notes. ESR
97 205, and LER 50 325/97-02 Core Saray Header Differential Pressure
Instrumentation Inoperable, to have 3een the normal condition since the
start of the current Unit 1 operating cycle.
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The inspector reviewed the last three performances of Maintenance ,
Surveillance Procedure IMST CS210, CS Sparger High dP Chan Cal. This I
test was'3erformed to assure CS sparger break detection instrumentation I
was opera)le in accordance with TS 4.5.3.1.c.2. In the December 4, 1996 j
and February 2E, 1997 tests, the inspector determined that the indicated ;
dP routinely exceeded normal expectations, therefore the alarm setpoint
was not verified to be within 5 i 1.5 psid of normal which was
identified as -154 inches of water. The inspector determined that if
the procedure had required actual verification of the alarm setpoint in I
relation to the indicated instrument pressure this nonconformance would
have been identified earlier.
TS 6.8.1.c requires that written procedures shall be established,
implemented, and maintained covering TS surveillance test activities of I
safety related equipment. The failure to have a procedure that
correctly implemented the TS 4.5.3.1.c.2 requirement that the CS Sparger
Break Detection alarm setpoint be within 5 1.5 psid greater than the
normal indicated pressure of 154 inches of water was identified as a
violation. This violation is identified as VIO 50 325/97 05 03,
Inadequate CS Surveillance Verification.
c. Conclusion
An Inspector Follow up Item was identified pending completion of NRC's
Review of licensee corrective actions and further investigation of the
problem. A violation was identified for the failure to verify the CS
sparger break detector alarm setpoint as required by TS.
MB Miscellaneous Maintenance Issues (92902)
M8.1 (Closed) LER 50 325/96 04: Standby Gas Treatment System Charcoal
Testino.
This voluntary LER was issued on April 19, 1996, to document the finding
that charcoal filters for the standby gas treatment system were not
tested in accordance with Regulatory Guide 1.52, Revision 1. as
specified in TS 4.6.6.1.b.2. This issue was identified on March 21,
1996, during the dual unit shutdown to repair problems with the service
water pumps. The Unit 1 startup was placed on hold by licensee
management pending resolution of this issue.
The issue was identified following information received by the NRC from
another utility who had identified this problem. Subsequent
investigation determined that vendor testing performed on the charcoal
for the Unit 1 standby gas treatment system was not in accordance with
Regulator Guide 1.52. Revision 1. The testing was conducted with pre-
loading, oading, and post loading temperatures of 80 degrees centigrade
(C) versus the required 25 degrees C pre and post load temperatures.
The vendor had provided the licensee certification that the testing was
performed in accordance with the requirements based on their ;
determination that the testing was equivalent. The performance of ;
believed equivalent testing by the vendor resulted in non compliance l
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with the requirements of TS 4.6.6.1.b.2, which was a violation. This
violation was identified as NCV 50 325/97 05 04, Charcoal Testing Not .
Performed in Accordance with TS Requirements. This non compliance
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constitutes a violation of minor significance, and is being treated as a ;
Non Cited Violation, consistent with Section IV of the NRC Enforcement
Policy. ;
On identification, the licensee had new samples of the Unit 1 charcoal
tested in accordance with the requirements of Regulatory Guide 1.52.
Revision 1. Successful testing was completed on March 23, 1996, prior
to the restart of Unit 1. Charcoal from Unit 2, which was still within
its 18 month surveillance window from installation, was sampled and
successfully tested. In addition to these immediate corrective actions, !
the licensee revised testing procedures for both the Unit 1 and Unit 2 l
standby gas treatment trains and control building emergency air l
filtration system charcoal filters, to specifically incorporate the l'
temperatures required in Regulatory Guide 1.52, Revision 1. These same
i changes were incorporated into the testing requests accompanying the
charcoal samples sent to the testing vendor. The inspector has reviewed I
this event and the completed corrective actions, and finds that with the
issuance of the above noted NCV, this issue is closed.
III. Enaineerina
E2 Engineering Support of Facilities and Equipment
E2.1 Rod Withdrawal Error Analysis !
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a. Inspection Scooe (37551) i
The inspector reviewed the issues concerning notification by the fuel
vendor that an inconsistency existed between the rod withdrawal error
(RWE) analysis assumptions and the TS operability requirements.
b. Observations and Findinas
The licensee was notified in a letter dated February 24, 1997, by the !
Boiling Water Reactor (BWR) vendor of a situation at another facility !
that could have similar implications at Brunswick. The letter indicated '
that the vendor had failed to notify another reactor licensee of the
need to issue a TS change request to control those conditions for which ,
the continuous withdrawal of a high worth control rod may cause fuel i
damage by exceeding the 1% plastic strain criteria. In a letter dated
March 10, 1997, the licensee was notified by the BWR vendor of the
results of a review of the Supplemental Reload Licensing Report (SRLR)
specific to Brunswick. This review indicated that a similar condition ,
existed at Brunswick for Cycle 10 on Unit 1. No discrepancies were
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identified for Unit 2 or the current Unit 1 operating cycle.
The Rod Block Monitor (RBM) suspends movement of a control rod in the
event of the im)royer withdrawal of that rod from an area of high
, density during liga power. The improper withdrawal of a high worth rod
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at high power would lead to fuel damage if the cladding plastic strain
exceeds 1% or if the safety limit minimum critical power ratio (MCPR)
was surpassed. The existing RBM TS 3rovided protection of the fuel from
exceeding the safety limit MCPR in tie operational condition by
requiring both RBM channels operable when greater than or equal to 90%
rated thermal power. No requirement existed in the Brunswick TS's to
maintain RBM operability to prevent exceeding the 1% plastic strain
criteria, despite the BWR vendor analysis taking credit for that ;
condition, i
The inspector reviewed the associated correspondence, CR 97 1277, RWE
analysis and TS. The licensee determined that on May 24, 1995, movement
of control rods while the RBM was inoperable was in accordance with TS.
During this occurrence the licensee contends that, despite movement of
the rods with the RBM ino)erable, conservatism built into the
calculation showed that t1e 1% plastic strain criteria was not exceeded.
The letter indicating the potential Brunswick discrepancy was received
by the licensee Nuclear Fuels Section and forwarded to site engineering
organization for concurrent review the day after receipt on March 10, 1
1997. Annotated on the letter was an indication dated March 11, 1997 l
that the Nuclear Fuels Section would initiate a CR. The inspector could
not locate a CR recording the nonconformance. The nonconformance was
finally entered into the corrective action program after discussions
between the inspector and the licensee on March 31, 1997, at 1:00 p.m.
concerning performance of an evaluation for reportability. Subsequently
the CR was evaluated and a reportability determination made. At
6:54 p.m. on March 31, the licensee made a four hour report to the NRC
in accordance with 10 CFR 50.72(b)(2)(iii)(D).
Plant Program Procedure OPLP-04, Corrective Action Management implements
the Corrective Action Management Policy for Brunswick. The procedure !
required consultation with the supervisor and initiation of a CR upon ;
identification of an operability concern or potential reportable event. '
The CR would serve to document the condition and actions taken, and the
possibility of an operability concern or reportable event. Potential
o)erability concerns or reportable events would then be evaluated by the i
S11ft Superintendent. Additionally, the CR served to provide proper I
classification and correction of adverse conditions, deficiencies, or
deviations by management processes based upon importance.
The inspector determined that a CR was not written promptly upon
identification of a potential operability concern or reportable event.
10 CFR 50 Appendix B, Criterion XVI Corrective Action, requires that
measures shall be established to assure that conditions adverse to
quality such as deficiencies, deviations, and nonconformances are
promptly identified and corrected. The failure to promptly initiate a
CR upon identification of a potential o)erability concern or reportable
event was identified as a violation. T11s violation will be identified
as VIO 50 325(324)/97 05 05, Timeliness of Operability and Reportability
Determination.
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c. Conclusions
The inspector reviewed the actions associated with the BWR vendor's
notification of an error in the SRLR for Unit 1. Licensee review
indicates that although rods were moved during RBM inoperability no i
safety limits were exceeded. The failure to promptly identify a l
nonconformance delayed evaluation of a potential operability concern or i
reportable event was identified as a violation. !
E3 Engineering Procedures and Documentation
E3.1 Improper Removal of Instrument Response Time Testing Requirements 1
a. Inspection Scone (37551)
The inspector reviewed the actions surrounding the deletion of
instrumentation response time testing requirements from the Updated
Final Safety Analysis Report (UFSAR) and subsequent notice of l
b. Observatiers i
In December 1993, the NRC issued Generic Letter (GL) 93 08 Relocation
of Technical Specification Tables of Instrument Response Time Limits.
The GL provided guidance for the relocation of instrument response time
limits from the TSs to the UFSAR. The licensee submitted a TS change
request in a letter dated April 14, 1994 which was supplemented on
May 16, 1994. The letters requested relocation of the instrument
response times to the UFSAR in accordance with GL 93 08. The request
was reviewed and subsequently approved by the NRC by Amendments 171 and i
202 to the operating license for Units 1 and 2 with the NRC Safety i
Evaluation Report included in a letter dated May 31, 1994.
The NRC, in a letter dated December 28, 1994 to the Boiling Water
Reactors Owners Group (BWROG) Chairman, concluded that selected
instrumentation response time testing (RTT) as identified in BWROG
Licensing Topical Report NED0-32291 A, System Analysis for Elimination
of Selected Response Time Testing Requirements could be deleted. The NRC
would accept the topical report as a reference in license amendments for '
those licensees adopting the NEDO recommendation to eliminate selected
instrumentation RTT, based on the conclusion that significant
degradation could be detected during the performance of other 1
surveillance tests, principally calibration tests. On February 14,
1995, the licensee, citing the NRC's approval of the NED0
recommendations deleted the RTT requirements for certain instruments
under the control of a 10 CFR 50.59 safety evaluation.
c. Findinas l
On March 21, 1997, the licensee was notified of a potential
noncompliance with the TSs. On March 20, 1997, Washington Nuclear Power
Station Unit 2 (WNP-2) entered into a TS 3.0.3 required shutdown due to l
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not performing RTT of selected Reactor Protection System (RPS),
Emergency Core Cooling System (ECCS), and Containment Isolation
Instrumentation. The noncompliance at WNP 2 resulted from the improper
deletion of those RTT requirements, which were previously located in TSs
from the UFSAR without NRC a> proval. Subsequent NRC review determined
that Brunswick had deleted tie RTT requirements located in the UFSAR in
the same manner as WNP 2. The licensee inappropriately made these i
changes based on NRC approval of the NED0 document, but did not make !
corresponding changes to the plant TS to indicate actual testing !
methods. I
The licensee reviewed the last performances of the RTT for those
instruments deleted from the UFSAR. The licensee determined that RTT
for selected instruments in the RPS, ECCS, and those used for
containment isolation had not been performed within the TS allotted
time. The licensee stated in their request for discretion that the
affected instrumentation was verified functional during the period of ,
nonconformance by the performance of channel functional, calibration and I
logic system functional tests. At 8:30 pm on March 21, 1997 in a i
telephone conversation with the NRC, the licensee requested the NRC i
exercise discretion in the enforcement of compliance with the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
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requirement to shutdown both units in TS Limiting Condition for i
Operation (LCO) for Sections 3.3.1, Reactor Protection System i
Instrumentation, 3.3.2. Isolation Actuation Instrumentation, and 3.3.3, l
Emergency Core Cooling System Actuation Instrumentation. In a letter to
the licensee dated March 25, 1997, the NRC staff acknowledged that the
equipment operability was assured by qualitative RTT performed on the l
deleted instruments in accordance with the NRC-anroved NEDO topical ;
report. Based on evaluation of the request the RC staff was satisfied
that granting the request involved minimal or no safety impact on public
health and safety. Therefore, the NRC staff exercised discretion not to
enforce compliance with the applicable TS sections. The Notice of
Enforcement Discretion was granted by the NRC staff by telephone at
9:36 p.m. and documented by the March 25, 1997 letter.
The inspector reviewed the TS, associated Engineering Service Requests,
TSs, unit log entries, and correspondence. The inspector verified that
the licensee approved the deletion of selected instrumentation RTT under
a 10 CFR 50.59 safety evaluation. UFSAR Change Request 94FSAR 100,
Deletion of RTT Requirements Per NED0 32291, documents this deletion.
The change analysis cites NRC approval of the NEDO topical report in the
10 CFR 50.59 evaluation. This issue is unresolved pending further NRC
review. This issue is identified as URI 50 325(324)/97 05 06, Deletion
of RTT Requirements.
d. Conclusions
The licensee as a result of a BWROG topical report deleted TS RPS, ECCS,
and Isolation Actuation response time testing. Subsequently, a notice
of enforcement discretion was issued due to the failure to perform
several response time test as required by TS. This issue is unresolved
pending further NRC review.
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E3.2 Soecial UFSAR Review
A recent discovery of a licensee o)erating the facility in a manner
contrary to the UFSAR description lighlighted the need for a special
focused review that compares plant practices, procedures, and/or
parameters to the UFSAR descriptions. While performing the inspections
discussed in this report, the inspectors reviewed the applicable
portions of the UFSAR that related to the areas inspected. The
inspectors verified that the UFSAR wording was consistent with the
observed plant practices, procedures, and/or parameters.
The inspectors reviewed the UFSAR change associated with instrument
response time testing requirements in paragraph E3.1. No additional
issues were identified.
IV. Plant Support
R1 Radiological Protection and Chemistry Controls
R1.1 Water Chemistry Controls
a. Inspection Scoce (84750)
The inspectors evaluated implementation of the licensee's water
chemistry program for control of primary system water quality. The
inspectors reviewed the specific 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 ppm and 2.0 mhos/cm,
respectively. TS 3.4.5 specifies that the specific activity of reactor
coolant be limited to less than or equal to 0.2 Ci/g dose equivalent
iodine (DEI).
b. Observations and Findinos
The inspectors reviewed the licensee's Procedure OAI 81, Water Chemistry
Guidelines, Revision No. 18, dated January 14, 1997, and determined that
it included provisions for sampling and analyzing reactor coolant at the
prescribed frequency for the parameters required to be monitored by TSs.
Action levels and responses for out of limit chemistry parameters were
also reviewed as described in 0AI 81. This procedure included provisions
for monitoring water quality based on established industry guidelines
and standards. The inspectors noted that the referenced licensee
procedure specified the sampling frequency and ty)1 cal values for each
parameter to be monitored. Action levels applica)le to various
operational modes were given where appropriate. Guidance was also
provided for actions to be taken if analytical results exceeded
prescribed limits. The inspectors determined that the above guidance
and procedures were consistent with applicable TS requirements.
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The inspectors reviewed chemistry statistical analysis reports, primary
chemistry data, related data trend plots, and records of analytical l
results for selected Unit 1 and Unit 2 parameters at power operations
and at shutdown during the period January 1, 1995 through March 4, 1997.
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The parameters selected included conductivity, chlorides, sulfates,
boron, zinc, and dose equivalent Iodine 131. A review of chemistry data
disclosed that the licensee exceeded water chemistry TS limits for
1
conductivity on April 20 and 21,1995 but the Unit 1 reactor vessel was l
defueled, the unit was in an outage, and the licensee was conducting a
full system chemical decon. The licensee was able to provide ,
documentation that verified an exemption had been granted to exceed TS :
limits by the NRC's Office of Nuclear Reactor Regulation based on the
licensee's amendment submittal approved by the NRC for these specific
conditions only. The licensee also entered administrative action levels
in accordance with 0AI 81 on numerous occasions during the period of
review indicating a parametric variance from normal values during power !
operations. In each case the inspector reviewed, the licensee was able l
to explain the variance in terms of an anomaly such as a reactor water
cleanup (RWCU) system trip, expended RWCU filters, or an evolution such l
as a reduction in the hydrogen water chemistry (HWC) injection rate.
c. Conclusions
Chemistry parameters were maintained well within TS and licensee
administrative limits. The licensee's water chemistry control program i
for monitoring water quality at specified surveillance frequencies had
been implemented in accordance with the licensee's TS requirements. l
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R1.2 Semiannual Radioactive Effluent Release Reoort l
a. Insoection Scope (84750)
TS 6.9.1.8 requires the licensee to submit a Semiannual Radioactive
Effluent Release Report covering licuid and gaseous effluent releases
resulting from facility operations curing each six months period of
prior operation. The report provided required estimates of radiation
doses to members of the public from effluents released to unrestricted :
areas. Data on solid radwaste shipments was also provided in the report
and evaluated. The licensee's program to monitor and control radiation
,
doses associated with effluent releases within TS 3.11 limits was
evaluated. The inspectors also evaluated effluent data to identify
adverse effluent trends, increases in estimated doses to the public from
effluents, if any, and explain these variances in the context of
operational experience,
b. Observations and findinos
Liquid and gaseous effluent data was developed from the licensee's
effluent release reports for the years 1994, 1995, and 1996. The
inspectors evaluated sup)orting raw data for effluent release reports
covering these years wit 1 emphasis on identifying elevated release
trends or data anomalies. As shown in the effluent release summary
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below, the amount of activity released during 1994, 1995, and 1996 in
liquid effluent streams remained relatively stable, at low levels, and
well within regulatory release limits. The amounts of activity released
during 1996 as fission gases, iodides, and particulates in gaseous
effluents was also at low levels and within release limits. Minor
variances in gaseous effluent parameters within operational limits were
identified between 1995 and 1996 indicative of normal steady state power
operations. No abnormal releases were identified during the period.
Brunswick Radioactive Effluent Release Summary
1994 1995 1996
Abnormal Releases
Liquid 0 0 0
Gaseous 0 0 0
Activity Released (curies)
a. Liquid
1. Fission and 0.045 0.415 0.04
Activation Products
2. Tritium 69.6 55.2 47.2
b. 'iaseous
1. Noble Gases 477 4330 713
2. Iodine 131 2.13E-03 5.32E-03 2.12E 02
3. Particulates 2.12E 02 2.24E 02 6.36E 03
4. Tritium 2.26E 01 3.66E 01 2.70E-01
As indicated above the curies of mixed fission and activation products I
were significantly elevated for 1995 in liquid releases due primarily to ]
the high activity from s)ent fuel shipping casks. The licensee
addressed this problem t1 rough improved control over cask washdown water
and the installation of a filter on the refuel floor to remove activity
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prior to introduction into the radwaste system. During 1996, the
i licensee achieved low levels of liquid effluents due to a liquid
l effluent reduction initiative that included the recovery of the floor
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drain collector filter system and cleanout of radwaste tanks and piping.
Accumulated sludge and debris from radwaste processing systems was
successfully removed. As a result of this radwaste processing system
upgrade project, a majority of floor and equipment drain quality water
was reclaimed resulting in a great reduct1on in liquid effluent volume
and curies. Less than three million gallons of radioactive liquid
effluents were released from radwaste (only 800,000 gallons released
from April through December 1996) as a result of this 3roject which
represents a record low release volume for the site (Tle site released
4.4 millirem gallons in 1995.)
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During 1995, noble gases released were elevated due to the 3resence of a
fuel leak in Unit 2 and problems associated with bypass leacage of a
Unit 2 offgas by) ass . valve. Successful licensee efforts to mitigate the
bypass valve pro)1em pending outage work precluded a significantly
greater gaseous release volume.
The inspectors evaluated 1994,1995, and 1996 hypothetical maximum
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annual dose estimates to the public from radioactive materials in
! gaseous and liquid effluent streams. Dose limits for the total body
from liquid effluents are given in TS 3.11.1.2. and limits for, doses
from gaseous effluents are provided'in TS 3.11.2.2 and TS 3.11.2.3.
Doses are calculated in accordance with the methodology in the Offsite
Dose Calculation Manual (0DCM) and are a function of the release point,
the isotopic mix, total curies released, and exposure pathways. All
calculated doses from liquid and gaseous releases were determined to be
less than 1 percent of the applicable TS dose limits and were calculated
- to be in a range of 0.03 percent to 0.4 percent of applicable TS limits.
! The inspectors evaluated current tritium concentrations in the
licensee's storm drain stabilization pond based on recent licensee
condition reports which identified an increasing trend in tritium
concentration in the pond. One sample well, ESS 2C., averaged monthly
, tritium concentrations during a recent twelve month period of
approximately 84,000 picocuries/ liter. The average tritium
concentration in the pond water from 1991 to the present was 8E-5
.
microcuries/cc which was below the 10 CFR Part 20 limit of IE-3
- microcurie /cc. However, in that the pond is unlined and elevated, there
is a hypothetical potential paMsay for tritium migration. Monitored
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releases within regulatory limits are currently made from.the pond
routinely via a ditch to the intake canal. To address the issue of
recent elevated tritium concentrations in the pond, the licensee plans
- an upgrade which would route turbine building condensate containing
) tritium to the plant's normal radwaste system for )rocessing instead of
the storm drain system which discharges to the sta)111zation pond.
Additional licensee actions contemplated include increased water
sam) ling and additional monitoring wells in potential migration
pat 1 ways. The inspectors evaluation of current licensee studies and
monitoring results identified no regulatory concerns. The inspectors
informed the licensee that the planned licensee activities which address
this issue will be further reviewed upon completion and the issue will
- be tracked as an Inspector Followup Item (IFI). IFI 50 325(324)/
97 05 07. Actions to Reduce Tritium in the Stabilization Pond.
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The licensee had undertaken initiatives to reduce solid radwaste volume
during 1996 and 1997. Efforts ongoing in radwaste generation
minimization include increased education and communication programs and
radwaste volume reduction / minimization initiatives. The licensee was
storing onsite all radwaste generated, including post processing
radwaste, due to the unavailability of offsite low level radwaste
storage. During 1996, the licensee generated 60,655 cubic feet of
radwaste, which was less than projected. During 1997, the licensee had
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generated 4825 cubic feet through February. The 1997 goal was 49,300
cubic feet (a one outage year).
c. Conclusions
The inspectors concluded that the licensee had maintained an effective !
program to monitor and control liquid and gaseous radioactive effluents '
and thereby limit doses to members of the public to a small percentage
of regulatory limits. The release of radioactive material to the .
environment from liquid and gaseous effluents for 1995 and 1996 was a !
small fraction of the 10 CFR 20, Appendix B and 10 CFR 50, Appendix I
limits. The projected offsite dose commitments which resulted from
plant liquid and gaseous effluents were well within limits specified in j
the TSs and the Offsite Dose Calculation Manual (0DCH). The results of
'
planned licensee activities to reduce tritium in the stabilization pond
will be reviewed in the future and tracked as an inspector followup
item. Radwaste minimization efforts were successfully reducing radwaste
volume with a significant reduction in the rate of radwaste generation i
evident from 1996 to 1997 year to date. '
R1.3 External Occupational Exoosure Control and Personal Dosimetry
a. Insoection Scope (837501
The inspectors evaluated the adequacy of licensee radiological. controls
with emphasis on external occupational exposure controls during normal
power operations. The inspectors made tours of the radiation controlled ;
areas, observed compliance of licensee personnel with radiation !
protection procedures for routine work evolutions, and conducted
interviews with licensee personnel with respect to knowledge of ,
radiological controls and working conditions. The inspectors evaluated
i
the adequacy of licensee commitnents to upgrade site dosimetry and l
wrsonnel monitoring programs to address NRC concerns identified in i
3runswick Unresolved Items 50 325(324)/96 16 03 for Lack of Accurate
Dose Tracking and Dose Assignment Practices and Related Procedures.
b. Observations and Findinas
The inspectors observed controls for external occupational ex osures ;
l which met applicable regulatory requirements and were designed to i
l maintain exposures As Low As Reasonably Achievable (ALARA). The '
l inspectors reviewed select radiation work permits (RWPs) utilized to I
!
control ongoing work within the radiation controlled area (RCA) and 1
noted that the rad controls observed were appropriate for the described - i
tasks and radiological conditions. Interviews were conducted with '
radiation workers in order to determine the level of understanding of
radiation work permit requirements from a re3resentative cross section
of plant workers. The inspectors observed tlat the workers interviewed
had signed onto an RWP. were wearing dosimetry appropriate to their work
activities within the RCA in accordance with plant 3rocedures, and were
performing specific work activities on appropriate RWPs. The workers
demonstrated an adequate knowledge of RWP requirements and of
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radiological working conditions. The ins)ectors continued to note ,
upgraded radiological posting practices tiroughout the plant. Pre job l
RWP work planning and ALARA briefings for observed ongoing work
evolutions were found to be conducted in an effective manner. During i
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tours of the plant, the inspectors observed RC technicians performing
radiation and contamination surveys in accordance with procedure. 1
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During a routine facility inspection walkdown on the morning of l
March 26, 1997, the inspectors toured the Radioactive Material Storage
Container Building (RMSCB) and identified a standard size five gallon
bucket that had the appearance of a new, unopened container. The
container was labelled " Activated Charcoal." With no radioactive ;
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material label evident. During questioning of licensee personnel in the
area, it was determined the bucket had alarmed the small article monitor
and measured approximately 1.3 million dpm. The inspectors requested I
that the contents be surveyed. Licensee personnel appropriately affixed i
a radioactive material label to the container as an immediate corrective
action necessary to identify the hazard. It was later determined that
the bucket contained highly contaminated components including a valve
which surveyed at 474,000 dpm and a bag of nuts and bolts that surveyed I
at 681,000 dpm. In addition to a radiological safety concern with
radioactive material found not controlled in accordance with labeling j
and storage procedures, the inspectors were additionally concerned that i
radiation workers had apparently not properly released the contaminated !
materials from a contaminated area prior to placement of the bucket in I
the RMSCB. Although not observed by the inspectors, the apparent i
improper transfer of highly contaminated material out of a contamination l
area (masked in what appeared to be a new container of activated
charcoal) indicated a disregard for contamination control procedures.
Upon discussion of these concerns with licensee management the licensee
indicated full agreement and initiated prompt and thorough corrective
actions. These actions included documentation of the findings as
condition reports requiring root cause analysis, proper disposition of
the improperly controlled container and its contents, initiation of an
investigation to determine the circumstances / origins of the bucket, and
a sitewide standdown with all site personnel regarding compliance with
the basic radiation protection principles violated. The circumstances
surrounding the movement of this highly contaminated valve from the work
area to the RMSCB are identified as an Unresolved Item pending ,
completion of the licensee's investigation. URI 50 325(324)/97 05 08.
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Movement of Unlabeled Container of Radioactive Material from Work Area
to RMSCB.
During inspection activity conducted during the period December 2 6,
1996, the inspector's evaluation of the licensee's dosimetry,
monitoring, and general radiation control procedures indicated the
licensee did not treat dose to occupational workers in buildings outside i
the RCA as occupational dose and that licensee procedures and practices
were generally deficient in this regard. Details of the issue are i
contained in Brunswick Inspection Report 96 16, dated January 2, 1997, l
in Paragraph R1.4 External Occupational Control and Personal Dosimetry. i
The licensee was unable to demonstrate adequately during the prior !
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inspection that occupational dose received by workers outside the RCA ,
(restricted area) was being considered .in the prospective analysis used
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to determine if workers required monitoring in accordance with the
requirements of 10 CFR 20.1502. In response to these findings the ;
- licensee documented the issues in condition reports, identified root !
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causes, and initiated significant corrective actions sufficient to
remedy the inspector's concern. These actions included: 1) Expansion of
the population of workers who will be issued a TLD to encompass all
- permanently assigned personnel at the site. This will involve the ,
assignment of approximately 200 additional TLDs: 2) Revised plant
, practices and related procedures to permit all workers assigned a TLD to i
take them home and wear at all times while on site: and 3) Revise the !
- practice of 100 percent " background radiation" subtraction as detected
at a RCA access point to a practice of subtracting natural background as :
detected at a remote point not influenced by turbine building radiation :
shine. Although planned corrective actions adequately address the
regulatory concerns identified during the prior inspection URI 50-
325(324)/96 16 03 will remain open pending licensee completion and l
implementation of needed dosimetry upgrades. ,
c. Conclusions
The radiological controls program .was being effectively implemented with
i generally good occupational exposure controls observed during normal
plant operating conditions. Good radiological control performance was
apparent in specific work activities observed by the inspectors. The .
licensee was effectively controlling operational site exposures to low
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levels during the period of inspection although sitewide dose !
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acrformance for 1996, at 702 person rem, remained relatively high. An !
Jnresolved Item was identified concerning the movement of a contaminated !
valve to a radioactive material storage area.
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R1.4 Transoortation of Radioactive Materials t
I a. Inspection Scope (86750) ;
The inspectors evaluated the licensee *s program for the preparation and
shipment of packages of radioactive materials in accordance with ;
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regulatory requirements and the licensee's radioactive material receipt l
and shi) ping procedure, HPS NGGC-0001, Rev. 4. dated February 17, 1997. !
10 CFR ) art 71 established the requirements for packaging, preparation 1
- for shipment, and transportation of licensed material. 10 CFR Part 71, !
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Subpart H, established the quality assurance (QA) program requirements
applicable to transportation of radioactive materials. 10 CFR Part
71.137 required the licensee to perform comarehensive, planned and :
- periodic audits to verify compliance with t1e QA program and to ;
determine the effectiveness of the program.
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b. Observations and Findinas !
The inspectors evaluated the licensee's preparation of packages for
transport including vendor services used for preparation and transport
of radwaste. Also reviewed were detailed checklists completed by the
licensee and vendors at the time of shipments to ensure proper l
packaging, labeling, and placarding of vehicles prior to shipping i
radioactive material offsite. The inspectors' determined that licensee's i
procedure for shipping radioactive materials included provisions for i
performing the required surveys and for assuring that the radiation and
contamination limits were met for each package offered for shipment.
Licensee's records for several shipments of radioactive material were
reviewed and it was found that the required surveys had been performed ;
and that radiation and contamination limits had been met. The inspectors '
determined that the licensee's procedures included provisions for
preparing shipping papers and manifests in accordance with requirements '
and for recording the required information thereon. The~ inspectors also
reviewed shipping papers for selected shipments of radioactive materials
and determined that they had been prepared in accordance with 3rocedure.
The inspectors determined that the licensee's procedures for slipping
radioactive materials included provisions for providing drivers with the
required instructions and that the shipping papers for selected
shipments included a copy of those instructions. The inspectors
determined that the licensee's procedures for shipping radioactive
materials included provisions for making recuired advance notifications !
and that the licensee's records for selectec shipments included copies
of the forms used to make the recuired notifications. The inspectors
reviewed selected shipping recorcs and determined that needed
information was being retained as required. The inspector's evaluated a :
1995 E&RC program assessment to determine if the licensee had met the ,
audit requirements of 10 CFR Part 71.137. The assessment was provided )
in response to the inspector's request to see an audit that met the I
s)ecific requirements of Part 71.137. The inspectors determined that l
tie assessment was broad in scope, covered multiple E&RC areas, but had i
very limited coverage of Part 71, Subpart H requirements, and did not
meet the regulatory intent of Part 71.137. The licenste stated that
despite the limited scope of the assessment reviewed they believed they
were in compliance when other audits in other quality assurance areas ,
were considered that could be tied to packaging and trans>ortation of I
radioactive material requirements. The licensee stated t1ey could i
demonstrate compliance and needed time to prepare a response. Review of
licensee documentation for compliance with 10 CFR Part 71.137 was
identified as an Unresolved Item URI 50 325(324)/97 05 09. Review !
Licensee Documentation for Compliance with Transportation of Rad
Material Audit Requirements.
c. Cpnclusions
Based on the above reviews and observations, it was concluded that the
licensee had implemented an effective program for packaging,
preparation, and transport of radioactive material in accordance with
regulatory requirements. One Unresolved Item was identified based on the
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need of the licensee to demonstrate compliance with 10 CFR Part 71.137
audit requirements.
P8 Miscellaneous Emergency Planning (EP) Issues (92904) '
!
P8.1 (Closed) LER 50-325/96 08: Hurricane Bertha at Brunswic h )
-
.
ThisLERwasissuedonAugust8,1996,torekorteventswhichoccurred
onsite due the impact of Hurricane Bertha, he site entered an Unusual
l Event (UE) on July 10, 1996, following the issuance of a hurricane
warning for the Brunswick County area by the National Weather Service.
Pre)arations were made to ready the site for the storm. In accordance
wit 1 site procedures, both units were taken to Cold Shutdown in
preparation for the storm's arrival. Due to power losses caused by the
storm, 29 of the 34 off site emergency notification sirens became
inoperable. A one hour notification was made in accordance with 10 CFR
50.72(b)(1)(v) when greater than seven sirens were determined to be l
inoperable. Additionally, a one hour event notification was made to ;
'
report the suspension of the roving security watches pursuant to 10 CFR
, 50.54(x). While the roving watches were suspended, additional measures
were established to maintain the requirements of the security plan. A
subsequent review of the event identified that the suspension of the
security watches and establishment of other measures constituted a 1
loggable event in accordance with 10 CFR 73.71. However, this did not
<
require invoking the provisions of 10 CFR 50.54(x). This issue, as well
as the actions taken were discussed with and reviewed by the Region II
security specialist inspector, and determined to be acceptable. The
issuance of this voluntary LER documenting this issue is considered
acceptable for closure of this item.
, P8.2 (Closed) LER 50-325/96-11: Hurricane Fran at Brunswick.
- This LER was issued on October 4, 1996, to report events which occurred
d
onsite due the impact of Hurricane Fran. The site entered an Unusual
Event on September 4, 1996, following the issuance of a hurricane
,
warning for the Brunswick County area by the National Weather Service.
.
Pre)arations were made to ready the site for the storm. In accordance
'
wit 1 site procedures, both units were taken to Cold Shutdown in ,
preparation for the storm's arrival. Due to power losses caused by the !
'
storm, 31 of the 34 off site emergency notification sirens became
inoperable. A one hour notification was made in accordance with 10 CFR
50.72(b)(1)(v) when greater than 7 sirens were determined to be
inoperable. Additionally, a one hour event notification was made to
1
report the suspension of the roving security watches pursuant to 10 CFR
50.54(x). .When the roving watches were suspended, additional measures
were taken to meet the requirements of the security plan. Despite these
efforts, a security alert was declared on September 5,1996, following
i the inability of two security cameras to monitor two protected area
, zones. For approximately 25 minutes, the requirements of security plan
i were unable to be met due to the immediate threat to personnel safety in
l posting compensatory guards to monitor the areas covered by the two
- cameras. Ca'nera coverage was restored approximately 25 minutes later.
.
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This uncompensated degradation of a safeguards system is a loggable
security event and meets the reportability requirements specified in 10 ,
CFR 73.71. This issue, as well as the actions taken were discussed with
and reviewed by the Region II security specialist inspector, and
determined to be acceptable. The issuance of this voluntary LER
documenting this issue is considered acceptable for closure of this '
item.
,
S1 Conduct of Security and Safeguards Activities
'
S1.1 Annual Security Assessment
'
a. Inspection Scone (71750)
The inspector reviewed the annual assessment relating to protected area
personnel access measures including equipment or pat-down searches for
illegal contraband.
b. Observations and Findinas ;
The inspectors reviewed the circumstances of CR 97-00794, dated
February 20, 1997, resulting from a Nuclear Assessment Section (NAS)
findings during the February 17-28, 1997, annual self assessment of the
security program. The NAS team conducted performance drills during the
evaluation and noted that the security officers responsible for .
conducting personnel and package searches prior to allowing access to I
the protected area (PA) failed to identify or aroperly handle devices l
introduced as contraband during two of the eig1t drills. As a result a l
potential existed for a weapon and explosive device to be introduced l
into the arotected area. However, these events were part of a drill and '
none of t1e devices were introduced into the PA. 1
i
Paragraph 7.0 of the Physical Security Plan (PSP), Revision 0, dated
March 15, 1996, requires "all )ersonnel, materials, packages (including
hand carried packages), shall 3e searched for firearms, explosives and 1
incendiary devices, prior to entry into the protected area." Paragraph
7.1 (3), of the PSP requires that a hands on search of any individual be
conducted when the search officer has a well founded suspicion that the .
individual may be carrying firearms, ' explosives, or incendiary devices.
Security procedure OSI 9 Personnel Access Authorization, Control and !
Identification, Revision 74, dated July 25, 1996, requires that " hand
held metal detector units and/or a pat-down search shall be performed to
the degree necessary to ensure detection of explosives, firearms, or
'
incendiary devices on these individuals who are not successfully
screened by the walk through detectors."
As noted above on two seaarate occasions during performance testing the
'
search officers responsi)le for ensuring that contraband was not
I introduced into the protected area failed to perform duties according to
regulatory requirements. Licensee management was responsive to this
issue and initiated action to upgrade training in this area. j
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24
c. Conclusions
'
The security personnel responsible for searching personnel and packages
! entering the protected area failed to properly identify and control .
l contraband. Additionally, work practices at the Primary and Secondary !
Access portals was not consistent with approved procedures and )lans.
This will be an inspector follow up item 50 325(324)/97-05 10 )ersonnel ,
Access Search Training.
V. Manaoement Meetinas i
l
l XI Exit Meetina Summary
The inspector presented the inspection results to members of licensee
management at the conclusion of the ins)ection on April 21, 1997. Post
inspection briefings were conducted on ,iarch 27, 1997. The licensee
acknowledged the findings presented.
,
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25 ;
PARTIAL LIST OF PERSONS CONTACTED
Licensee
G. Barnes, Manager Training '
C. Barnhill, Dosimetry Supervisor, E&RC
A. Brittain, Manager Security
.
W. Campbell, Vice President, Brunswick Steam Electric Plant
1
R. Crate, Superintendent, Radiation Protection
B. Deacy. Outage Planning Manager
N. Gannon, Manager Maintenance
J. Gawron, Manager Nuclear Assessment
D. Holder, Supervisor, Radwaste Programs
K. Jury, Manager Regulatory Affairs
'
W. Levis, Director Site Operations
- B. Lindgren, Manager Site Support Services
R. Lopriore, General Plant Manager ,
- .J. Lyash, Brunswick Engineering Support Section
i B. Nurnburger, Superintendent, Environmental and Chemistry
- C. Pardee Manager Operations
G. Raker, Senior Analyst. Environmental and Chemistry -
D. Pacini, Radiation Control Supervisor
"
i P. Sawyer, Radiation Control Supervisor '
R. Schlichter, Manager Environmental and Radiation Control
S. Tabor, Senior Specialist. Regulatory Affairs
J. Terry, Program Analyst E&RC
M. Turkal, Supervisor Licensing and Regulatory Programs
Other licensee employees or contractors included office, operation, '
maintenance, chemistry, radiation, and corporate personnel.
E. Brown
C. Patterson
W. Rankin
D. Thompson
K. Barr
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26 L
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 61726: Surveillance Observations -
IP 62707: Maintenance Observations
, IP 71707: Plant Operations
- IP 71750
- Plant Support Activities
IP 83750: Occupational Radiation Exposure
IP 84740: Radwaste Treatment Effluent & Environmental Mon.
IP 86750: Transportation of Radioactive Material ,
IP 92901: Followup Operations '
IP 92902: Followup Maintenance
IP 92904: Followup - Plant Support
ITEMS OPENED, CLOSED, AND DISCUSSED l
Ooened
50 324/97 05 01 NCV Missed Jet Pump Surveillance (paragraph 08.1)
50 325/97 05 02 IFI Abnormal CS Sparger Break Detector Indication .
(paragraph M3.1) !
50 325/97 05 03 VIO Inadequate CS Surveillance Verification
(paragraph M3.1)
50-325/97 05 04 NCV Charcoal Testing Not Performed in Accordance
with TS Requirements (paragraph M8.1)
50 325(324)/97-05-05 VIO Timeliness of Operability and Reportability
Determination (paragraph E2.1) l
l
l
50-325(324)/97 05 06 URI Deletion of RTT Requirements (paragraph E3.1)
50 325(324)/97 05 07 IFI Actions to Reduce Tritium in Stabilization Pond
(paragraph R1.2)
50 325(324)/97-05 08 URI Movement of Highly Contaminated Valve from Work
Area to Storage (paragraph R1.3) ,
50 325(324)/97 05 09 URI Review Licensee Documentation for Compliance .;
with Transportation of Rad Material Audit ;
Requirements per 10 CFR 71.137 (paragraph R1.4)
'
50 325(324)/97-05-10 IFI Personnel Access Search Training (paragraph ,
S1.1)
e
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27
Closed :
50 324/97 05-01 NCV Missed Jet Pump Surveillance (paragraph 08.1)
50 324/96 04 LER Jet Pump Surveillance Not Performed Prior to
Exceeding 25% Reactor Power (paragraph 08.1)
50 325/96 04 LER Standby Gas Treatment System Charcoal Testing
(paragraph M8.1)
50-325/97 05-04 NCV Charcoal Testing Not Performed in Accordance :
with TS Requirements (paragraph M8.1) !
50-325/96 08 LER Hurricane Bertha at Brunswick (paragraph P8.1)
50 325/96 11 LER Hurricane Fran at Brunswick (paragraph P8.2)
!
'
Discussed
50-324/96-03 01 LER Operation in Excess of Maximum Power Level ,
Specified in Operating License (paragraph 08.2)
50-3?5(324)/97 02 02 URI Recirculation Pump Transients (paragraph 08.3)
50 325(324)/96-16 03 URI Unresolved Item for Lack of Accurate Dose
Tracking and Dose Assignment Practices and
Related Procedures (paragraph R1.3)
50 325/97 02 LER Core Spray Header Differential Pressure ,
Instrumentation Inoperable (paragraph H3.1) l
,
1
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