ML080710526

Notification of Inspection and Request for Information

ML080710526
Person / Time
Site:	Brunswick
Issue date:	03/10/2008
From:	Brian Bonser NRC/RGN-II/DRS/PSB1
To:	Waldrep B Carolina Power & Light Co
References
Download: ML080710526 (8)

Text

March 10, 2008 Carolina Power and Light Company ATTN: Mr. Benjamin C. Waldrep, Vice President Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION

Dear Mr. Waldrep:

During the period of June 16-20, 2008, the NRC will perform the baseline Public Radiation Safety Cornerstone inspection at Brunswick, comprised of NRC Inspection Procedures 71121.03, Radiation Monitoring Instrumentation and Protective Equipment; 71122.01, Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems; and 71122.03, Radiological Environmental Monitoring Program and Radioactive Material Control Program. The NRC will also perform sections of Inspection Procedure 71151, Performance Indicator Verification, and as it applies to public radiation safety.

Experience has shown that this inspection is resource intensive both for the NRC inspectors and your staff. In order to minimize the impact to your on-site resources and to ensure a productive inspection, we have enclosed a request for documents needed for this inspection. It is important that all of these documents are up-to-date and complete, in order to minimize the number of additional documents requested during the preparation and/or the onsite portions of the inspection. In lieu of a pre-inspection visit, we request that the requested information be provided to our staff by May 19, 2008. An address to which the information, preferably on CD, can be sent is provided on the enclosed document request.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Lee Grzeck of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector, Heather J. Gepford at (404) 562-4659.

In accordance with 10 CFR 2.390 of the NRC=s ARules of Practice,@ a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system

CP&L 2

(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/

reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62

Enclosure:

Pre-Inspection Document Request (cc: w/encl See page 3)

CP&L 3

cc w/encl:

Director, Site Operations Brunswick Steam Electric Plant Carolina Power & Light Company P. O. Box 10429 Southport, NC 28461-0429 Benjamin C. Waldrep Vice President Brunswick Steam Electric Plant Carolina Power & Light Company Electronic Mail Distribution Paul Fulford Manager Performance Evaluation and Regulatory Affairs PEB5 Carolina Power & Light Company Electronic Mail Distribution Edward L. Wills, Jr.

Plant General Manager Brunswick Steam Electric Plant Carolina Power and Light Company Electronic Mail Distribution Donald L. Griffith Manager Brunswick Steam Electric Plant Progress Energy Carolinas, Inc.

Electronic Mail Distribution Randy C. Ivey Manager Support Services Brunswick Steam Electric Plant Progress Energy Carolinas, Inc.

Electronic Mail Distribution Garry D. Miller Manager License Renewal Progress Energy Electronic Mail Distribution James Ross Nuclear Energy Institute Electronic Mail Distribution John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC 20037-1128 Beverly Hall Chief Radiation Protection Section N.C. Department of Environmental Commerce & Natural Resources Electronic Mail Distribution Peggy Force Assistant Attorney General State of North Carolina P.O. Box 629 Raleigh, NC 27602 Public Service Commission State of South Carolina P.O. Box 11649 Columbia, SC 29211 David R. Sandifer Brunswick County Board of Commissioners P.O. Box 249 Bolivia, NC 28422 Warren Lee Emergency Management Director New Hanover County Department of Emergency Management 230 Government Center Drive Suite 115 Wilmington, NC 28403

Enclosure Pre-Inspection Document Request Public Radiation Safety Cornerstone Licensee:

Brunswick Nuclear Plant Docket Number(s):

50-324, 325 Inspection Dates:

June 16-20, 2008 Inspection Procedures to be performed:

71122.01 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 71122.03 Radiological Environmental Monitoring Program (REMP) and Radioactive Material Control Program 71121.03 Radiation Monitoring Instrumentation and Protective Equipment 71151 Performance Indicator Verification (public radiation safety)

The most recent inspection completed for inspection procedures 71122.01, 71122.03, and 71121.03 was September 2006. The most recent inspection for inspection procedure 71151 was March 2007. Documentation is requested from the date of the previous inspection to the present.

We would prefer as much of the information as possible in electronic form. An index to the CD contents is also helpful. For those items requesting a list of documents/areas, the inspectors will select documents/areas from the list for on-site review.

If you have any questions, please call Heather Gepford at 404-562-4659. Thank you in advance for all your effort in putting together this material.

Assistance Requested During On-Site Inspection Identification of work activities during the inspection for inspector observations, including notification of pre-job briefings.

Advance notification of any liquid or gaseous effluent releases, including the associated pre-release sampling, analysis, and permit generation.

Health physics assistance in plant walk-downs assessing access controls, e.g. verifying the posting and locking of entrances to HDR-HRA and VHRA, and spent fuel pool controls.

Assistance in plant/area walk-downs including: (1) liquid and gaseous effluent systems and associated effluent/process radiation monitors, (2) radiation monitors, including ARMs, CAMs, whole body counters, personnel contamination monitors, etc., (3) meteorological equipment, (4) groundwater monitoring locations including wells, manways, etc.

Enclosure 2

Assistance with observations of REMP sample collection and processing.

General Information Request Telephone numbers of contacts Plant, Radiation Protection, and Chemistry organizational charts Electronic copy of applicable chapters of UFSAR (e.g. radiation protection program, effluents and environmental monitoring programs, radiation monitoring system, etc.)

Latest revision of the Offsite Dose Calculation Manual (ODCM)

List of radiation protection and chemistry (i.e. effluents) procedures Most recent DAW 10 CFR Part 61 analytical results.

Corrective Action Program procedures Audits and self-assessments performed since the last inspection that encompass the areas of (1) radiation protection, (2) effluent treatment and monitoring program (including chemistry and count room), (3) radiological environmental monitoring program, (4) radioactive material control, (5) meteorological monitoring program, (6) groundwater monitoring, (7) radiation measurement instrumentation program (fixed and portable), and (8) respiratory protection program.

71122.03: Radiological Environmental Monitoring Program (REMP) and Radioactive Material Control Program Site and corporate procedures associated with the REMP program, meteorological monitoring, and radioactive material control program. These procedures should include:

o Environmental sampling methodology for each matrix (e.g. TLD, ground and surface water, milk, vegetation, sediment, etc.) including sample collection, preparation, and analysis o Calibration and maintenance of sampling equipment o Calibration and QC activities for sample counting instruments o Calibration, maintenance, and routine surveillance of meteorological instruments o Control, survey and release of individuals and materials from the RCA o Response to alarms at RCA and/or protected area exits o Calibration, maintenance, and use of small article monitors, tool monitors, etc.

Two most recent Annual Environmental Monitoring Reports Calibration and maintenance records for air samplers and composite water samplers.

Calibration records for environmental sample counting instruments, including control charts and LLD determination OR audits of quality control program of vendor laboratory used to analyze REMP samples, as appropriate.

Interlaboratory comparison program results for the past two years (in-house laboratory or vendor laboratory). For in-house counting lab, quality control evaluation of results.

Calibration/surveillance/maintenance records for the meteorological instruments since the last inspection.

List of small article monitors, tool monitors, etc. and their locations (calibration records for select instruments will be requested by the inspectors after reviewing the list).

List of corrective action reports generated since the last inspection related to the REMP and Radioactive Material Control program, including the following:

Enclosure 3

o REMP program, including sampling and sample analysis o Meteorological monitoring program, including sensor problems, tower unavailability and data transmission/display discrepancies o Radioactive material control 71122.01 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems Site and corporate procedures/manuals associated with the radioactive effluents treatment and monitoring program. Procedures/manuals should include:

o Calibration and routine surveillance procedures for the effluent monitors listed below, including set-point determination.

o HP/Chemistry/Operations procedures for liquid and gaseous effluent sampling, analysis, and release, including release permit generation o Calibration and use of the effluent sample counting laboratory instruments (gamma spectroscopy, liquid scintillation, gas proportional) o Counting laboratory QC activities, including daily/weekly calibration checks, control charts, and interlaboratory comparison performance o Surveillance activities on air treatment systems, including charcoal/HEPA filter testing o Calculation of projected doses to members of the public from effluent releases Procedures for onsite/offsite surface/groundwater monitoring activities and leak detection Two most recent Annual Radioactive Effluents Release Reports.

Summary of spill, leak, or unexpected liquid discharge data documented in the sites 10 CFR 50.75(g) files.

Two most recent calibrations for the following effluent monitors, including flow meter calibrations:

o Unit 1 Condenser Off-Gas Radiation Monitoring System o Main Stack Radiation Monitoring System o Liquid Process Radiation Monitoring System Unit 2 Reactor Building Ventilation Radiation Monitoring System List of time periods during which the above listed effluent monitors were out of service since the last inspection.

List of modifications and design changes, including procedural or operational changes, made to effluent treatment, monitoring, or sampling systems or to plant ventilation systems since the last inspection.

Most recent liquid and gaseous continuous release permits and most recent liquid and gaseous batch release permits (4 total).

Two most recent surveillances of the air cleanup system for the routine main plant airborne effluent release pathway including flow rate and HEPA/charcoal efficiency.

Interlaboratory comparison program results for effluent sample counting laboratory since the last inspection.

List of corrective action reports generated since the last inspection related to effluent monitoring equipment, effluent treatment systems, and air cleanup systems.

List of corrective action reports generated since the last inspection for tritium or other radioisotopes in ground water wells, or identification of spills or leaks from contaminated systems, structures, and components.

Available for onsite review by inspector during inspection:

Plant drawings sufficient to permit the inspector to walk-down the liquid and gaseous effluent processing systems and effluent/process radiation monitors.

Enclosure 4

Description and/or 50.59 evaluations of modifications and design changes, including procedural or operational changes, made to effluent treatment, monitoring, or sampling systems or to plant ventilation systems since the last inspection.

71121.03 Radiation Monitoring Instrumentation and Protective Equipment Site and corporate procedures/manuals associated with radiation monitoring instrumentation and respiratory protection. Procedures/manuals should include:

o Operation, calibration, and maintenance of ARM, CAM, portal monitor (PM),

personnel contamination monitor (PCM), and tool monitors, including set-point determination o Operation and calibration of Whole Body Counter (WBC) equipment o Issuance/operation of portable survey instruments o Calibration and maintenance of portable instruments (e.g. ion chambers, friskers, teletectors, rem-ball) o Actions to be taken when portable instrument found to be significantly out of tolerance/calibration o Issuance and use of respiratory protective equipment (emphasis on SCBA and air-supplied equipment) o Training, including fit-testing, for use of SCBA and supplied-air systems o SCBA maintenance activities, including vital components (i.e. regulators) o Determination/verification of Grade D air for SCBA If PASS capabilities have been modified through license amendment, provide a copy of the amendment and applicable SER Two most recent surveillances of PASS equipment (or equivalent equipment as approved by license amendment)

Two most recent calibrations for the following area radiation monitor (ARM) equipment:

o Unit 1 TIP Room ARM (Channel 1-21) o Unit 1 Between Reactor & Fuel Pool Elevation 1174 ARM (Channel 1-28) o Unit 2 Radwaste Drum Storage ARM (Channel 2-8) o Unit 2 Turbine West Moisture Separator Drain Tanks ARM (Channel 2-12) o Unit 2 2B Core Spray Pump Room ESS II ARM (Channel 2-16)

Two most recent calibrations for PCMs and PMs located at the RCA exit.

Most recent calibration of WBC and copy of the analysis library.

Records of certification of air quality for equipment used to provide breathing air for air-supplied respirators and SCBA bottles since the last inspection.

List of corrective action reports generated since the last inspection involving radiation monitoring and protective equipment deficiencies, including the following:

o Area radiation monitors and continuous air monitors o Portable instrumentation, PCM, PM, and WBC monitoring equipment o Respiratory protection equipment and program implementation.

Available for onsite review by inspector during inspection:

Inventory, inspection, and maintenance records for SCBA equipment Training records, including fit-testing, for SCBA-qualified individuals Training records/certification for individuals qualified to perform maintenance on vital components (e.g. regulators) on SCBA

5 Enclosure 71151 Performance Indicator (PI) Verification Procedure(s) for identifying, notification, tracking, and correcting PI occurrences Monthly PI reports since February 2007, and copies of associated corrective action reports for RETS/ODCM Radiological Effluent occurrences All final release point effluent monitor out-of-service dates since March 2007.

Inspector Contact Information:

Heather J. Gepford, Ph.D., CHP (404) 562-4659 Heather.Gepford@nrc.gov Mailing Address US NRC Region II ATTN: Heather J. Gepford 61 Forsyth Street, SW Suite 23T85 Atlanta, GA 30303-3415