IR 05000324/1982003
| ML20052C395 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/22/1982 |
| From: | Albright R, Barr K, Wray J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20052C365 | List: |
| References | |
| 50-324-82-03, 50-324-82-3, 50-325-82-03, 50-325-82-3, NUDOCS 8205040750 | |
| Download: ML20052C395 (8) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION n
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REGION il o,
101 MARIETTA ST., N.W., SUITE 3100
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ATLANTA,GEORotA 30303 Report Nos. 50-325/82-03 and 50-324/82-03 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: Brunswick Steam Electric Plant Docket Nos. 50-325 and 50-324 License Nos. DPR-71 and DPR-62 Inspection at Brunswick site near Southport, NC Inspectors:
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. Wray Dp'te Siefned I
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. H. Albright D' ate Signed
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Approved by:
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K. P. Barr, Section Chief Date/ Signed Technical Inspection Branch Engineering and Technical inspection Division SUMMARY Inspection on January 25-29, 1982 Areas Inspected This routine, unannounced _ inspection involved 64 inspector-hours on site in the
. areas of internal and external exposure control, respiratory protection, per-sonnel contamination control, radwaste shipping and gaseous waste discharges.
Results Of the six areas inspected, no violations or deviations were identified in five areas; one violation was found in one area (failure to follow procedures -
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paragraphs 6 and 8).
l 8205040750 820420 PDR ADOCK 05000324 G
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l REPORT DETAILS 1.
Persons Contacted Licensee Employees
- C. R. Dietz, General Manager
- R. E. Morgan, Plant Operations Manager
- G. J. Oliver, Environmental and Radiation Control Manager L. F. Tripp, Radiation Control Supervisor R. F. Queener, Project Specialist, Radiation Control R. D. Pasteur, Environmental and Chemistry Supervisor J. B. Cook, RC&T Foreman B. Failor, RC&T Foreman J. Henderson, RC&T Foreman
- R. White, QA/QC Specialist
- D. E. Novotny, Regulatory Compliance, Senior Specialist R. M. Poulk, Regulatory Specialist NRC Resident Inspector
- L. W. Garner
- Attended exit interview
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2.
Exit Interview The inspection scope and findings were summarized on January 29, 1982, with those persons indicated in paragraph 1 above. The General Manager acknowl-edged the violation but stated, with regard to the drywell entry procedure citation, that the radiological conditions of the drywell had been estab-lished by RC&T personnel during an initial entry and that additional pro-tection would not have been afforded by a special drywell entry RWP. The inspector stated that the drywell entry procedure requires a separate _ RWP for each entry into the drywell when the reactor is critical to assure appropriate health physics control and that the 7-day standing.RWP did not satisfy this requirement.
The General Manager also acknowledged the inspector's concerns regarding the licensee's personnel contamination control program. He stated that a frisker station surveillance program will be established to ensure proper whole body frisking when leaving protective
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clothing required areas and that names of personnel found to be contaminated i
at various frisking stations will be recorded and compared to the personnel decontamination log to ensure that all contaminated individuals report for decontamination promptly.
3.
Licensee Action on Previous Inspection Findings t
Not inspected.
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Unresolved Items Unresolved items were not identified during this inspection.
5.
Licensee Action on Previous Inspector Followup Items (Closed)(80-45-07): Develop programs for adequate beta dosimetry and skin dose assessments.
The licensee is using a state of the art beta gamma dosimetry system. The licensee has also developed a program to assess skin dose when personnel are contaminated.
The beta dosimetry system and the beta skin dose assessment program appear to be adequate for beta exposure assessment.
(Closed) (80-45-12):
Establish firm requirements for when a whole body count is required. The inspector reviewed the revised whole body counting procedure and found it to have sufficient detail to describe when whole body counting is required.
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(Closed) (80-45-13): Provide regulated power to the whole body counter and reduce background variations. The licensee has installed a regulated power supply for the whole body counter.
In addition personnel have been instructed not to conduct whole body counts when the background is high enough to interfere with the counting. The inspector observed the alerming instrument in the whole body counting room used to determine high back-ground.
(Closed) (80-45-14):
Provide onsite availability and evaluation of whole body count data.
Whole body count data is now maintained onsite in individual dosimetry files and is available for evaluation of the respiratory program effectiveness. ~ The inspector had no further questions.
6.
External Exposure Control The inspectors reviewed procedures and records in order to determine the adequacy of the licensee external exposure control program._ Review of exposure records for the first three quarters of 1981 revealed numerous errors in the birthdates and one record indicated that an individual accumulated 3.108 rem during the first quarter of 1981.
The inspector reviewed this individual's dosimetry file with a licensee representative in -
order to determine the discrepancy and found th't the individual's previous a
quarter offsite exposure of 1.554 rem had been entered into the data base twice.
No violations or deviations of NRC exposure limits or regulations were found.
The dosimetry files of the five highest exposures in 1981 were reviewed.
This review indicated that an investigation, as required by plant proce-dures, was conducted anytime the thermoluminescent dosimeter (TLD) and pocket dosimeter (PD) totals differed by greater than 25% and either dosimeter had accumulated more than 500 mrem since the last TLD reading.
For the above circumstances, the procedure required that a QA check be
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performed on the TLD.
If this check indicated that the TLD was within specifications, the pocket dosimeter totals were generally discarded. Only in some cases, as determined by a Radiation Control and Test (RC&T) foreman, was there an investigation by interview, Radiation Work Permit (RWP) review or comparison of doses with fellow workers. The inspector expressed concern that some TLDs are read several times per month and the comparison investigation for TLD and pocket dosimeter totals is not required when either the TLD or pocket dosimeter reads less than 500 mR. This could lead to an underestimation of actual exposure. The inspector stated that a more thorough investigation of PD/TLD differences greater than 25% should be conducted when either the PD or TLD reads greater than 500 mR in one month.
The inspector reviewed preliminary changes to procedures which will require a more detailed PD/TLD investigation and stated that these procedures will be reviewed at a later date (50-324/82-03-01 and 50-325/82-03-01),
The inspector requested the dosimetry section to provide a list of personnel who had been credited with neutron exposure during January 1982.
The neutron exposures during January 1982 were the result of Unit 2 drywell entries with the reactor critical. Initial drywell entries after shutdown and drywell entries with the reactor critical are made under procedure RC&T-0261.
This procedure requires that a RWP will be initiated for the above types of drywell entires.
The inspector reviewed RWP's for January 1982 and found that 5 of 8 individuals who received neutron exposure during January 1982 were not signed in on a RWP written specifically for drywell entry when the reactor was critical. A licensee representative investigated and found that these five individuals were signed in on a 7-day, standing RWP for routine inspection and operation. A review of the standing RWP indicated that neutron surveys were not applicable; therefore, the standing RWP was not satisfactory when there was a potential for neutron exposure. The General Manager disagreed and stated that the radiological conditions of the drywell had been established by RC&T personnel curing an initial entry and that additional protection would not have been afforded by a special drywell entry RWP. It is the inspector's position that this entry into the drywell with the reactor critical in order to check for leaks is not a routine operation.
Technical Sepcification 6.11 requires that procedures for personnel radi-ation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all oper-ations involving personnel radiation exposure.
The inspector stated that entering the drywell under a standing RWP with the reactor critical is a failure to follow procedure RC&T-0261, paragraph 8 in violation of Technical Specification 6.11 (50-324/82-03-02 and 50-325/82-03-02).
The standing RWP should only be valid for areas where radiological conditions are known and do not have a high potential for change.
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licensee should define areas where the radiological conditions have demon-strated the potential to become airborne, significantly change radiation levels, to charge conditicns due to the work going on in an area or. areas-where a health physics technician is required in order to assess the hazards L
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prior to an entry.
In the above types of areas, the 7-day standing RWP should be invalid (50-324/82-03-03 and 50-325/82-03-03).
The inspector found RWP's written for drywell entry with the reactor critical and compared the names on the RWP's with those individuals who had been credited with neutron exposure. Two individuals out of 6 checked had not been credited with neutron exposure. A licensee representative located the record of the neutron exposure calculation but the record had not been routed to the dosimetry section. The licensee prepared procedure revisions as corrective action. The inspector reviewed the preliminary revision and stated that it appears to be adequate. This item will be followed up after PNSC review (50-324/82-03-04 and 50-325/82-03-04).
The inspectors reviewed the 7-day standing RWP sign-in sheet and found it to L
be inadequate because the sheet does not include space for the date or the
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name of the area entered.
The lack of specific information on the RWP
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greatly reduces the value of the RWP for exposure control or investigative purposes.
The 7-day standing RWP sign-in sheet should be revised to show the date and area entered (50-324/82-03-05 and 50-325/82-03-05).
7.
Internal Exposure Control The inspectors reviewed procedures and records in order to determine the adequacy of the licensee's internal exposure control program. A computer
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listing of whole body count results for the first three quarters of 1981 rnd selected whole body counts for January 1982 indicated that no worker was internally exposed to levels of radioactivity in excess of the regulatory limits in 10 CFR 20.103. The inspector had no further questions.
8.
Respiratory Protection The inspectors compared the licensee's respiratory protection program to the internal exposure program and found no discrepancies.
Respiratory protec-tion is prescribed for any job which has a potential for creating airborne contamination. A RC&T foreman must give approval for anyone to enter an area of greater than.25 MPC without respiratory protection. The licensee appeared to be successfully controlling MPC-hrs to less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day and 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per week.
The inspector reviewed the dosimetry files of 12 personnel who signed in on RWP's. requiring respiratory protection. One individual's file was incom-plete and indicated that he had net received respirator practical fit
. training as required by procedure RC&T-0220, paragraph 8.3.
Based on interviews and record reviews the licensee and the inspector determined that the individual had received the proper training.
The inspector stated, however, that not documenting respirator practical fit training in the individual's official record prior to the respirator being issued was failure to follow procedure RC&T-0220, paragraph 8.3.
This is another
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example of failure to follow procedures in violation of Technical Speci-fication 6.11 (50-324/82-03-02 and 50-325/82-03-02).
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9.
Radioactive Waste Shipments a.
The inspector reviewed the shipping documents for radwaste shipment 82-027, 12 dumpsters containing non-compacted trash. The inspectors made an independent rcdiation survey at contact and six feet from the sides of the truck, as well as in the cab of the truck, and found no readings above DOT limits. A review of the records for this shipment indicated the same results. The inspector had no further questions.
b.
The inspector reviewed the shipping documents for radwaste shipment 82-025, 170 cubic feet of dewatered resin in a Type B 14-195H cask.
The shipment contained 10.165 curies.
Radiation and contamination surveys indicated no values greater than NRC or DOT limits.
The inspector had no further questions.
c.
The inspector, accompanied by licensee representatives opened six containers of compacted trash packaged and ready for shipment.
No freestanding liquid was evident.
No radiological problems were encountered.
10. Gaseous Waste Discharges Effective December 24, 1981, the Brunswick site Environmental Technical Specifications were amended which altered the method whereby radioactive waste discharges of noble gases are determined to be in compliance with regulatory objectives.
The inspector discussed with licensee representa-tives the procedures and systems established to ensure that releases of
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radioactive noble gases do not exceed the new limit. The new equations have been programmed into a computer and continuously plotting release data makes available an adequate amount of information so that no release limits can be approached without sufficient warning. The inspector reviewed release data since Cecember 12, 1981, which indicated that all radioactive gaseous releases were within technical specification limits.
No violations or
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deviations were found.
11.
Personnel Contamination Control a.
On September 4, 1981, the licensee notified Region II (letter No. 81-1449) that it was suspending the requirement for periodic whole body frisking at the exits of the radiation control area in favor of tandom use of a newly acquired G-M detector hand and foot monitor and a a liquid scintillation portal monitor.
The inspector reviewed data generated by the licensee which indicated that the new hand and foot monitors are detecting hand and foot contamination which was missed by personnel whole body performed frisks at the breezeway and radwaste building exit.
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The licensee conducted experiments which indicated sensitivity levels of approximately 7000 dpm per hand and 16000 dpm per foot for the hand and foot monitor based on 16 second counts.
Licensee representatives stated that the RM-14/HP-210 frisker provided sensitivities of approxi-mately 15,000 dpm for a small spot of contamination in comparable background and frisking speed (10-12 cm/sec). The licensee also stated
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that if the activity were evenly distributed, the frisker could reliably detect approximately 25,000 dpm per 100 sq. cm. Licensee data also indicated that the liquid scintillation portal monitor could reliably detect approximately 1.0E+06 dpm gamma if evenly distributed over the entire body surface.
The inspector stated that each instrument used to survey personnel for contamination has a specific purpose. While the new hand and foot monitor and scintillation portal monitor have proven useful, they do not perform as efficient a whole body survey as an adequate RM-14/HP-210 scan for spot contamination.
Proper use of all three instruments should ensure that no individual could leave the plant contaminated above station limits The inspector stated that prior to letter
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No. 81-1449, the Health Physics department maintained control of personnel whole body frisking with the RM-14/HP-210 instrument at the radiation control area exits. At present, proper whole body frisking is not controlled at each dress out area.
The inspector stated that the new portal monitor and hand and foot monitor provide confidence in the contamination control program only when proper whole body frisks are performed when leaving a contaminated area.
The General Manager
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stated that a program will be established to periodically audit dress out areas for proper frisking techniques (50-324/82-03-06 and 50-325/82-03-06).
b.
The inspector reviewed decontamination logs for January 5 and 6,1982,
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and compared them to contamination cases identified and logged at the
radiation control area exits. Many workers found to be contaminated at
the plant exit did not appear on decontamination records.
It is understood and acknowledged by most plant workers that the facility has a Rb-88 problem and that if contaminated with Rb-88, waiting approxi-
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mately one hour for decay will eliminate the hazard.
The lack of correlation between contamination instances and decontamination entries seems to imply.that many workers assume their contamination is Rb-88 and wait one hour some place other than the decontamination area. The inspector expressed concern that such a mindset on the part of plant employees may mask cases of real contamination and, unknowingly, workers may track this contamination into undesirable locations (e.g.,
lunch room, lavatories, offices, etc.).
The General Manager stated
that a program will be established to record names of individuals found to be contaminated at the breezeway and radwaste loading dock exits and that these names will be routinely compared to decontamination logs to ensure timely reporting of contaminated individuals for decontamination (50-324/82-03-07 and 50-325/82-03-07).
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12. Strontium-90 Source Incident a.
The inspectors investigated an incident which occurred in December 1981 when a 20 millicurie Sr-90 portable instrument calibration source arrived at the Brunswick site warehouse. Warehouse personnel notified RC&T personnel that a source had been received. A RC&T technician was dispatched to do a receipt survey on the package. 10 CFR 20.205(c)(1)
specifies that a survey must be performed as soon as practicable after receipt of greater than 50 millicuries of Transport Group II,- Type A material. Therefore, a survey upon receipt of this package did not appear to be required.
The technician used a gamma scintillation instrument to survey the package and obtained readings of 1.15 mR/hr on contact with the box. The package was opened and a thin metal can containing the source was removed. The source container was stored in an unoccupied area for five days prior to RC&T personnel retrieving the source from the warehouse. At that time, a radiation survey performed with an ionization chamber instrument yielded readings of 15 R/hr beta / gamma o r. contact with the source container.
The licensee conducted an investigation and assigned doses based on survey results and stay time records to the exposed, unmonitored personnel. Warehouse personnel, who are outside the protected area, are not required to be monitored pursuant to 10 CFR 20.202(a).
The inspectors performed an independent radiation survey using an NRC ionization chamber instru-ment.
Survey data obtained compared favorably with licensee results.
The inspectors stated that the doses assigned to the exposed warehouse personnel appeared to be appropriate.
No personnel overexposures occurred.
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Based on discussions with another licensee who had received an iden-tical source from the same manufacturer, the licensee determined that the source was incorrectly packaged, labeled and shipped.
For the other licensee, the identical source was shipped in a plexiglass container in order to shield the betas and prevent bremsstrahlung generation.
The inspectors agreed that the source appeared to be packaged improperly causing unnecessary radiation exposures.
Region III is investigating the shipment with the manufacturer at their home plant. The inspectors reviewed the liceasee's evaluation of the incident and stated that it appeared to be adequate. No violations or deviations were found pursuant to Carolina Power and Light Company in this area.