IR 05000324/1985039

Insp Repts 50-324/85-39 & 50-325/85-39 on 851216-20.No Violations or Deviations Noted.Major Areas Inspected: External Exposure Control,Program to Maintain Exposure ALARA & Solid Wastes

ML20205J234
Person / Time
Site:	Brunswick
Issue date:	01/18/1986
From:	Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205J227	List: IR 05000324/1985039 ML20205J225
References
50-324-85-39, 50-325-85-39, NUDOCS 8601300130
Download: ML20205J234 (8)

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pa neeu UNITE 3 STATES 4 4 NUCLEAR REGULATORY COMMIS510N

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[ REGION il 3 y 101 MARIETTA STREET, N W

• * ATLANT A, GEORGI A 30323

% , , , . . #' JAN 2 4 IM Report Nos.: 50-325/85-39 and 50-324/85-39

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Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2 Inspection Co ducted: Dec 6-20, 1985 Inspector /// / -/ 7-d/o T T.~ CoopTr 7 Date Signed Approved by: C/AT !r 7LtA/) /!/J'[f[p C. M. Hosey, Secti )n Chief Date Signed Division of Radi ation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection involved 41 inspector-hours onsite in the areas of external exposure control, program to maintain exposure as low as reasonably achievable (ALARA) and solid waste Results: No violations or deviations were identifie G601300130 060124 4 DR ADOCK 050

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REPORT DETAILS ' Persons Contacted Licensee Employees P. Howe, Vice President, Brunswick Nuclear Project

• J. Chase, Assistant to the General Manager

• T. Wyllie, Manager, Engineering and Construction -

• R. Groover, BCU Manager

• Allen, Technical Aide, Regulatory Compliance

• Poulk, Jr. , Sr. Specialist, Regulatory Compliance

• L. Tripp, Radiation Control Supervisor

"J. Henderson, Radiation Control Supervisor  !

• J. Terry, Project Specialist, ALARA

• J. Guido, BCU ALARA

• Dorman, QA/QC Supervisor

• C, Martin, ONS

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• A. Hegler, Operations Superintendent

• E. Eckstein, Acting Manager, Maintenance l

• A. Cheatham, Manager, Environmental and Radiation Control '

"R. Queener, Principle Specialist, Radiation Control G. Worley, Radiation Control Foreman C. Barnhill, Radiation Control Foreman T. Priest, Radiation Control Foreman T. Sherrill, Radiation Control Foreman B. Conn, Radiation Control Foreman

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Other licensee employees contacted included 25 construction craf tsmen,10 ,

technicians, 2 operators, 8 mechanics, 3 security force members, .and 5 office personne * Attended exit interview i Exit Interview The inspection scope and findings were summarized on December 20, 1985, with those persons indicated in paragraph 1 above. The plant program to keep exposures as low as resonably achievable (ALARA) was discussed in detail with Ilcensee management (paragraph 5). The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters (Closed) Violation (50-324/85-17-01) Establish procedures fer solid waste r systems to insure complianee with 61.56(a)(3). The inspector reviewed and verified the corrective action as stated in Carolina Power and Light ,

Company's letter of August 22, 198 I t

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4. External Occupational Dose Control and Personal Dosimetry (83724)

During plant tours, the inspector checked the security of the locks at two locked high radiation areas and observed posting of survey results and the use of controls specified on three radiation work permits (RWPs). Use of Dosimeters and Controls The licensee was required by 10 CFR 19.13, 20.101, 20.102, 20.201(b),

20.202, 20.402, 20.403, 20.405, 20.407 and 20.408 to maintain worker's doses below specified levels and keep records of and make reports of

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dose The licensee was required by 10 CFR 20.203 and Technical Specification 6.12 to post and control access to radiation area Final Safety Analysis Report (FSAR) Chapter 12 also contained commitments regarding dosimetry and dose control During observation of work in the plant, the inspector observed the wearing of thermo1Jminescent dosimeters (TL0s) and pocket dosimeters by worker The inspector discussed the assignment and use of dosimeters with

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radiation protection technicians, Radiation Control Foremen and Radiation Control Supervisor During plant tours, the inspector observed the posting of areas and made independent radiation measurements to assure proper posting. The inspector reviewed recent changes to plant procedures regarding the use of TLDs and dosimeters. The licensee had recently implemented a program whereby TL0s are analyzed on a quarterly basis. The licensee monitored the external exposure of personnel as accumulated by pocket dosimeter and tracked by dose cards. When any individual's accumulated exposure approached 500 millf rem (mrem) as measured by the pocket dosimeter, the individual's TLD was read and the exposure was recorded in the dosimetry files. If the individual was not exposed to 500 mrem of ionizing radiation di ring the quarter, the TLD was processed routinely at the end of the quarter and any exposure recorded in the individual's dosimetry file, Dosimetry Results The inspector reviewed the Form NRC-5 equivalent printout for the fourth quarter of 1985. The licensee currently had 2,700 individuals badged at the facility. The licensee had established an administrative whole body exposure limit of four rem for any worker at the facilit The inspector examined the exposure records for 15 individuals who were approaching the licensee's administrative limi The inspector examined records of five cases of lost dosimeters to evaluate the methods and conclusions regarding the assignment of dos Management Review of Dosimetry Results The inspector discussed the dostmotry results with four maintenance supervisors and two radiation control foremen, concentrating on their

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1 assigned staff to determine their understanding of radiological controls for their staf No violations or deviations were identified.

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5. Maintaining Occupational Doses ALARA (83528)

l 10 CFR 20.1(c) specified that licensee > should implement programs to keep worker's doses ALARA. FSAR Chapter 12 also contaired licensee commitments regarding worker ALARA actions, Worker and Supervisor Actions The inspector discussed dose control measures with six workers on the job and four maintenance and two health physics supervisors to determine their degree of involvement in dose reduction. The inspector discussed with the supervisors their actions to reduce individual and collective doses, concentrating particularly on staff members with the highest doses. The inspector also discussed their actions to set dose goals for tasks, methods used to reduce doses, and techniques used to

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monitor performance against goals. One estatononce foreman stated that l a graph showing the accumulated exposures for each maintenance crew was l

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maintained in the maintenance shop area. He stated that this was used to equalize the dose each crew received, i.e. , if one crew was nearing the administrative limit for the quarter, the crew with the lower accumulated dose would be assigned to the task. The inspector discussed exposure reduction techniques such as use of shleiding, the use of mock-uos and training with licensee representatives. The l licensee representative stated that such items would be considered for

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appilcability to specific job The inspector interviewed other station personnel on their understanding of ALARA. One plant employee stated that he used the ALARA printout generatt.d each week as a management tool. He stated that he would review a:ach of his employee's exposures and if one or more employees had little or no exposure, he would assume they were not performing their job. The inspector discussed this statement with the

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Site Vice-President and the acting Plant Manager. Both agreed that at I

one time this was a misconception among some plant employees and that efforts had been made to change that attitud During various interviews, the inspector found that foremen did not l generally monitor the preparation and execution of tasks to which their personnel were assigne Licensee management stated that this was due to the large amount of administrative type work the first If ne supervisors were required to perform. Licensee management also stated l that measures had recently been implemented which would relieve these I supervisors of most of their administrative tasks and allow them to more closely supervise their personne . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ - - _ - _ _ _ _ . _ _ _ _ _ _ - _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

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i ALARA Design Guide

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The Engineering Department was in the process of procedura11 zing an l ALARA Design Guide. This guide was for use by any engineer when ,

designing a plant modification. The plant ALARA group was involved in '

the formalization of this guide which was to consist of a checklist of  !

ALARA items to be considered by the engineer when a modification is in the design phase of preparation. The use of such a checklist by design personnel would assist in assuring that ALARA concerns would be .

considered prior to the time the ALARA group is required to review the modificatio The inspector discussed the following ALARA item in detail with I licensee representatives:  !

Completion of the ALARA post-job review process: In 1984, i approximately 220 ALARA evaluations were performed by the ALARA grou Of these, 29 evaluations or 13 percent of the ALARA reviews performed received a post-job critique. In 1985, approximately 150 ALARA  ;

evaluations were performed with two or 1 percent receiving a post job critiqu The inspector discussed the following additional ALARA program items I with licensee representatives. At the conclusion of the discussion, a Ifcensee representative stated that these items would be evaluate (1) Accelerate the number of supervisory personnel attending the General Employee Training (GET) Level III classes: The GET Level III training offered by the licensee was for Advanced Rad-Worker Certification at the licensee's facility. The ALARA .

portion of this training appeared comprehensive and may increase the individual's awareness of ALAR (2) Provide detailed training for those personnel involved in the  !

man-rem budgeting process, provide for review by multiple levels of management to present a realistic estimate of the expected personnel exposures to prevent deliberate man-rem overbudgeting:

Provide training to individuals on how to use historical data to research previous type work to aid in the budgeting process. A licensee representative stated that he thought that at times, a foreman or supervisor would send an individual to request an RWP in which the man-rem associated with that work would exceed the licensee ALARA review level of one man rem. He stated that the worter would request the RWP and the foreman or supervisor would never review the request. An unrealistic man-rem estimate on the part of the worker requesting the RWP would promulgate a call from the ALARA group to the responsible supervisor when the ALARA group reviewed the reques ;

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(3) Procedura1tre and implement the Engineering ALARA Design Guide: 3 As discussed in paragraph 5(b), the guide would provide for the  :

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ALARA review of a plant modification by the cognizant engineer ,

I during the design phase of preparation.

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(4) Expand and implement a Maintenance Rework Tracking Program f Ouring the time of this inspection, this program was in Standard .

l Operating Procedure (50P) form in use in the Maintenance  ;

l Departmen Interviews with plant personnel indicated that

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maintenance reworks were a significant contributor to the -

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facility's external exposur '

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(5) Review the possibility of implementing a positive control program '

such as radiation safety violations or a similar program for unapproved actions which contribute to the licensee s accumulated <

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external exposure (6) Insure that lines of communication are estabitshed and functional '

down the chain of command from the area manager to the  ;

supervisors, foreman and workers. During interviews with plant personnel, the inspector found that although the plant management ,

was very sensitive to ALARA, this same sensitivity was not evident '

at the foreman and worker level ;

(7) Document tailgate meetings which include ALARA discussions with a copy of the meeting minutes to the ALARA Coordinator: The  ;

Itcensee uttilzed crew type industrial and radiological safety l meetings, termed " tailgate" meetings. Documentation of ALARA

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discussions would Indicate to the ALARA Coordinator whether pertinent ALARA discussions were being conducte (8) Establish low background waiting areas inside the Reactor Building (RB): During plant tours, the inspector noted that no low background waiting areas were established in the R8 for the '

purpose of staging personnel or equipment prior to the start of wor The inspector observed crewfs staging in an area where the ,

dose rates ranged from 20 to 50 millf rem per hour (ares /hr) when l 10 feet away, the dose rates dropped to 2 to 5 mres/h Designation of such areas would amount to significant exposure -

reductions over the course of an extended outag l (9) Examine the traf fic patterns currently in use in the R8: Entry  !

into the R8 from the Turbine Building required that personnel pass (

through an area where the dose rates range from 5 mrom/hr to 50  ;

mrom/h ;

(10) Establish a control point outside the R8: The licensee performed !

respirator issue, RWP review, maintained change out areas and other control point activities in an area of the R8 where the dose >

rates are two to five mres/hr. Relocation of some of these  ;

activities to the turbine building or other low background area l could also result in significant exposure savings during an l extended outag l l

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(11) Combine the two ALARA groups operating onsite into one group: Two ALARA groups were in place at the licensee's facility. One group was the facility ALARA group and ' reports to the Radiation Protection Manager. The second ALARA group reports to the construction side of the facility operation. Combination of these two groups would facilitate a free flow of information and would provide for the review of all ALARA issues by one management chai These items will be reviewed during future inspections (50-325/85-39-01).

No violations or deviations were identifie As of December 19, 1985, the actual collective exposure for calendar year 1985 was 3,039 man-rem which represented 108 percent of the estimated exposure for the yea . Licensee Audits and Surveillances (83722, 83723, 83724, 83725, 83726, 83728, 84722, and 86721)

The inspector discussed the audit and surveillance program related to radiation protection, radioactive waste . management and transportation of radioactive material with licensee representatives. The inspector reviewed the following audits and surveillances: , Corporate Health Physics Audit of the Facility ALARA program, September, 1985 Corporate Health Physics Audit of the Plant Radioactive Waste and

' Shipping Program, June 25, 1985 Corporate Quality Assurance Audit CQAD-85-1660, August 21, 1985, review, evaluation, and verification of implementation of the CP&L CQAP Manual, BSEP Licensee and Technical Specifications and BSEP commitments, Corporate Quality Assurance Audit CQAD-85-858, Aprl) 26,1985, review, evaluation and verification of implementation of the BSEP FSAR, BSEP Technical Specifications and CP&L Corporate QA Progra No violations or deviations were identifie . Solid Waste (84722)

10 CFR 20.311 required a licensee who transfers radioactive waste to a land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.5 If further established specific requirem1nts for conducting a quality control program and for maintaining a manifest tracking system for all shipment The inspector reviewed the methods used by the licensee to assure that waste was properly classified, met the waste forms and characteristics required by

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I 10 CFR 61 and met the disposal site license condition The use of these methods was discussed with licensee representative .

The inspector reviewed selected manifests prepared for waste shipments made during November 1985 to verify that a tracking system was used to insure that shipments arrived at the intended destination without undue delay.

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No violations or deviations were identifie ?

i Facility Statistics kl As of December 19, 1985, the ifcensee had made 103 shipments of radioactive I waste consisting of 45,018 cubic feet of waste containing 2,427 curies of

! activit The current inventory of radioactive waste on site was 6,644 i cubic fee l

Personnel contamination in 1985 numbered 172 which was a 90% decline from l the 1984 leve '

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l l Plant contaminated areas totaled 91,336 square feet which was 50 percent of <

the 1984 leve '

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