IR 05000324/1987028

Insp Repts 50-325/87-28 & 50-324/87-28 on 870817-21.No Violations or Deviations Noted.Major Areas Inspected: Organization & Mgt Controls,Training & Qualifications, External & Internal Exposure Control & Surveys

ML20238F497
Person / Time
Site:	Brunswick
Issue date:	09/03/1987
From:	Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20238F492	List: IR 05000324/1987028 ML20238F489
References
50-324-87-28, 50-325-87-28, NUDOCS 8709160193
Download: ML20238F497 (13)

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I pR HEcuq UNITED STATES

. 4 4 NUCLEAR REGULATORY COMMISSION '

[\' T$ REGION 11 101 MARIETTA FTREET,rt g j

• 't ATLANTA, GEORGI A 30323

% , , , . **' SEP 101997 Report No.: 50-325/87-28 and 50-324/87-28 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 Inspection Conducted: August 17-21, 1987 Inspector: Er,tb 3 Rt, M A l Date Signed 6 C. H. Basgett (

Accompanying personnel: R. Shortridge Approved by,: Mry tD f _, 3 C 4./,n17N fnC.N.hosey,hectionChief Date sSigned Division of Rddiation Safety and Safeguards

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SUMMARY Scope: This was a routine unannounced inspection in the area of radiation protection including: organization and management controls; training and qualifications; external exposure control; internal exposure control; control of radioactive material and contamination, surveys, and monitoring; facilities and equipment; transportation of radioactive material; radiological controls for drywell; the program for maintaining exposures as low as reasonably achievable (ALARA)andinspectorfollowupitem Results: No violations or deviations were identifie PDR ADOCK 05000324 G PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• P. W. Howe, Vice President, Brunswick Nuclear Project

• C. R. Dietz, General Manager

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

• T. H. Wyllie, Manager, Engineering and Construction

• R. E. Helme, Director, Onsite Nuclear Safety

• L. E. Jones, Director, Quality Assurance / Quality Control

• W. M. Hogle, Engineering Supervisor, Technical Support

• R. M. Poulk, Jr., Senior Specialist, Regulatory Compliance

• W. J. Dorman, Supervisor, Quality Assurance

• B. Altman, Principal Engineering, Maintenance

• L. F. Tripp, Supervisor RC-1, Environmental and Radiation Control

• R. F. Queener, Principal Engineer, Radiological G. Speight, Radiological Staff Engineer, Corporate Health Physics R. E. Pennock, Training Coordinator, Health Physics J. F. Terry, ALARA Coordinator, Health Physics G. L. Worley, Radwaste Foreman C. T. Barnhill, Dosimetry Foreman T. M. Sherrill, Instrument and Repair Foreman J. L. Kiser, Project Specialist, Health Physics P. B. Snead, Senior Specialist, Health Physics

P. A. Gallager, Senior Specialist, Health Physics Other licensee employees contacted included engineers, technicians, security office members and office personne Nuclear Regulatory Commission

• Ruland, Senior Resident Inspector

• Attended exit interview

, Exit Interview

The inspection scope and findings were summarized on August 21, 1987, with those persons indicated in Paragraph 1 above. The licensee acknowledged the inspection findings and took no exception. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.

l Licensee Action on Previous Enforcement Matters l

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4. Organization and Management Controls (83722) Organization The licensee was required by Technical Specification (TS) 6.2.2 to implement the facility organization specified in TS Figure 6.2.2- The responsibility, authority and other management controls necessary for establishing and maintaining a health physics program for the facility were outlined in Chapters 12 and 13 of the Final Safety Analysis Report (FSAR).

The inspector reviewed the plant organization with the Environmental and Radiation Control (E&RC) Manager to determine the degree of support received from other members of management and the lines of communication and authority. It appeared that the support required to implement and maintain an effective radiation control program was in plac No violations or deviations were identified, Staffing Technical Specification 6.2 specified minimum staffing for the plan FSAR Chapters 12 and 13 also outlined further details on staffin The inspector reviewed the health physics organization and staffing with the E&RC Manager. The attrition rate, use of contractor health physics technicians, current staffing levels and qualifications were discussed. The attrition rate of the Health Physics (HP) staff has l been low, resulting in an increased level of experience and familiarity with plant operation No violations or deviations were identifie l Controls The inspector reviewed the licensee's program for identifying and l '

correcting radiological / safety problem Operating Experience i Reports (0ERs) were written as a followup to serious incidents that led or could have led to overexposure, ingestion of radioactive j

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material or other radiological problems. E&RC Experience Reports l

were written concerning conditions or events not documented by other report Radiation Safety Violations (RSVs) were used to document _

problems of lesser significance which, if not corrected, could cause !

l more serious problem Weekly management tours and tours by the HP l l

technical staff were other means used to identify radiological i problem The inspector noted that the effectiveness of the RSC program could be improve The RSVs often addressed the symptoms of a problem but not the root caus Also, it appeared that only the HP organization was participating in the program whereas the program was designed for

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use by ' all ' plant groups. It.was also noted that the RSV program could be.used to emphasize and strengthen the program for. maintaining exposures as low as reasonably achievable (ALARA) (see Paragraph 10).

No violations or deviations were identifie . Training'anoQualification(83723)

The inspector reviewed Operating Experience Report (0ER) No. 87-02 The report -discussed the events surrounding an incident in which a-Radiation Control (RC) technician allowed individuals to work in a highly contaminated area without respiratory protection (see Paragraph 7.d).

Training records of the RC technicians in charge of radiological controls during the event were reviewed to' determine the adequacy of training.- The review of training records revealed that the technicians had received both classroom and on-the-job training in tasks such as, performance of pre-job surveys, selection of respiratory equipment, and responding to changing radiological conditions in a work area. The training in responding to changing radiological conditions was reviewed in detail. The lesson plan contained appropriate' learning objectives and the learning objectives were measured by specific tests. The RC technicians qualification cards were examined and reflected satisfactory accomplishment of training for the subject task. ' The review showed the amount and content of the training should have been adequate to prevent such an even The licensee- factored lessons : learned from the event into training by reviewing the event with chemistry and RC technicians at training sessions and placing a summary of the event in the required reading fil No violations or deviations were identifie . External Exposure Control and Dosimetry (83724) Use of Dosimeters and Postings The licensee was required by 10 CFR 19.13, 20.101. 20.102, 20.201(b),

20.202, 20.401, 20.403, 20.405, 20.407, and 20.408, to maintain worker 3' doses below specified levels and keep records of and make reports of doses. The licensee was required by 10 CFR 20.203 and TS 6.12 to post specified areas and control access to plant area .

I FSAR Chapter 12 also contained commitments regarding dosimetry and dose control. During observation of work in the plant, the inspector noted the wearing of thermoluminescent dosimeters (TLDs) and self-reading pocket dosimeters (SRPDs) by worker The inspector discussed the assignment and use of dosimeters with workers,

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radiation protection technicians, radiation control foremen, x and

' radiation control supervisor 'During plant tours, the inspector observed the posting of areas and made in& pendent radiation measurements using NRC equipment to assure proper [ posting. The inspector checked the security of the locks at four locked high radiation area The inspector also observed posting of survey. results and the use of controls specified on four radiation work permits (RWPs).

No violations or deviations were identified.

! Dosimetry Results and Administrative Controls The inspector reviewed the Form NRC-5 equivalent printout through August 18, 1987. The licensee had approximately 2,100 individuals badged at the facility. Of those individuals listed, 20 had received exposure in excess of 2,000 millirem for the year and I had rwceived in excess of 3,100 millirem for the yea No one, however, had exceeded any quarterly dose limit The inspector also reviewed selected TLD-SRPD discrepancy, reports and TLD-SRPD Lost /0ffscale investigation ', No violations or deviations were identifie s Radiation Work Permit Program The inspector reviewed the program for requesting, preparing, approving, and implementing RWPs. For routine work, a presubmittal RWP form is completed by the person requesting or planning the job and the form is given to a radiation control technician specializing in RWP preparation and control. After an ALARA review and, if necessary, radiation, contamination and airborne level surveys, the RWP is writte It is then approved by an RC foreman end issued for wor Changes to an RWP dealing with changing radiological conditions or relaxing protective clothing requirements require an RC foreman revie The inspector reviewed selected RWPs and surveys completed in support of the work governed by the RWP No violations or deviati ns were identifie . Internal Exposure Control and Assessment (83725)

The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, and 20.403 to control intakes of radioactive material, assess such intakes and keep records of and make reports of such intakes. Chapter 12 of the FSAR also included commitments regarding internal exposure control and assessmen ,

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5 Control Measures During plant tours, the inspector observed the use of temporary ventilation systems, containment enclosures, and respirators. The inspector discussed the use, issue and return of respiratory equipment with licensee personnel. Medical examinations prior to respirator use and fit testing were also discussed. The licensee now uses a local hospital to perform the medical evaluations throughout the year instead of an outside vendor who brought in a mobile l laboratory for one month a yea No violations or deviations were identifie Intake Assessments Through records review and discussions with licensee representatives, it was determined that during 1987, no personnel required intake evaluations due to receiving greater than 40 Maximum Permissible Concentration-hours (MPC-hours) in one week. Four individuals had intakes which resulted in organ burdens greater than ten percent (10%) Maximum Permissible Organ Burden (MP0B). The inspector reviewed the evaluation of these intakes which indicated that the workers received MPC-hours ranging from 9.65 to 26.53 and cumulative dose equivalents ranging from 7.1 millirem to 95.8 millirem (see Paragraph 7d below for details of the intake event).

No violations or deviations were identifie Breathing Air The inspector discussed with licensee representatives their procedures for ensuring the quality of the air supplied to airline respirator The same sources of air was used for both plant instrument air and breathing air. However, the instrument air was passed through a dryer while the breathing air was not dried. Air quality was checked every three months to ensure Grade D air was maintained and a sample was sent offsite to be tested for hydrocarbon Air quality was also checked for the presence of radionuclides before a breathing air manifold was placed into servic No violations or deviations were identifie Review of Licensee Event The inspector reviewed OER No.87-023, which detailed an event that retulted in the internal contamination of six workers. The Unit I reactor vessel head had been reinstalled following refueling and the outer cavity bellows area was drained in preparation for installation of the drywell dome. On May 8,1987, a mair+anance refueling crew entered the cavity to install studs, nuts, t > washers in the flange

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area ,of . t@j d' ome. The radiition ~ work permit ( #(RWP) 87-1234,

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Revition14b req' u ired af full set'of protective clothing, a chest TLD <

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f At approximately 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />, as the crew of seven mechanics eitered

.?the cavity, an initiaVair sariple indicated an airborne radioactivity ylevel of 9.5 E-10 microcu"Jes.per cubic centimeter-(uCi/cc) or less (Sthan twenty-five percent 0f f the maximum permissibic. dcdcentration

(less than 25% MPC). Thirty nr]nutes* *later,

during installation of the nvM on the studs, 'a second air 'rdmple1was taken which read

, 10,000; cpm on an RM-14. frisker. The job was stopped and the area ev>ict e,te The air . sample analysis dhowed airborne particulate -

aStivity of 4.7 E-8 uC/cc (1.59 MPC)! Six of seven workers, after r/cetving a whole body count,,shbyid internal' contamination from t0624.4 percent of a maximuw permissible organ burden (MP0B).-

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i An 11vestigation conducted by the licensee showed that a survey of '

the work area taken at 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> the morning of'the incident

. differed greatly from the radiological data listed on the RWP. While radiation levels were slightly lower those reported on the RWP, contamination , levels were much higher, ranging from

\60,000dpm/100cm2 te 640 millirad per hour per one hundred square

' ' centimeters (mrad /hr/100 cm2). The investigation also showed tnat pne-job evaluation by the radiological control technician relied

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L ~ heavily on historical data at the expense of the current survey dat / As a result, workers were sent'tb work in an area with greater than

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100 mrad /hr/100/cm2 smearable contamination levels without L

respiratory protection. The RC technician covering the job stated l; that he had done so as a rewit of his previous experience on similar jo h and to the as low as re uonably achievable (ALARA) philosophy to

, @lminate the unnecessary and burdensome use of respirators.,

As. corrective actions the licensee required: (1) that all cavity work'be performed in respirators for the remainder of the outage; (2)

t$t di procedure change be made requiring the use of respirators for v/ork in areas greater than 50,000 disintegrations per minute per one  ;

' hundred square centimeters (dpm/100 cm2) smearable, contamination; (3) '

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.that RC Foreman ' approval be required on all RWPUfor any relaxation i

of protection equipment requirements and (4) that the incident be t reviewed with all chemistry and RC technicians, q .

10 CFR 20.201(b) requires that each licensee make or/cause to be made [ , q such gurveys as may be necessary for the licensee to conpig with the / a re9ubtions in this part and are reasonable under the incur: stances j to evaluate the extent. of the radiation hazards that may'be preseqt., j A survey is defined as an evd.uation of the radinton hazards ( 1 incident to the production, use, release, disposal or presence of radioactive materials under a specific set of condition The licensee was informed that the frilure to conduct an adequate evaluation to the radiological haztrds present in the' flange area of the drywell dome would normily be considered a' violation of L '

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10 CFR 20.201(b). However, the NRC Enforcement Policy,10 CFR 2,

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Appendix C, states that a Notice of Violation will generally not be issued f violations identified by the licensee, if (1) it was f identin.:v by the licensee; (2) it fits in Severity Level IV'or. V; g -

/ y:( f (3)it4 was reported, if required; (4) it was or will be corrected, g includin jf " and -(5) itg wasmeasures to prevent not a violation recurrence, that could within reasonably a reasonable be expected to time;

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i have been prevented by the licensee's. corrective actions for a

' u previour ) violatio The inspector stated that this apparent a i

viclition met the criteria specified in 10 CFR 2, Appendix C and I

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wouM be considered licensee identifie ?

The inspect 9e reviewed the corrective actions taken by the licensee )

. and determined that they had been implemented or completed and that  !

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ll.~ Control of Radioactive Materials ' and Contamination, Su rveys , and l

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Monitoring, (83726)

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r x The licensee was required by 10 CFR 20.201(b) and 20.401 to perfonn

!~ surveys and to maintain records of such surveys necessary to show

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a compliance with regulatory limit Survey methods and instrumentation were outlined in FSAR Chapter 12 , while Technical f

.)%t Specifications 6.8 and 6.11 provided requirements for adherence to

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( i During plant tours, the inspector examined radiation levels and

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contamination survey results outside selected rooms and cubicles,

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The inspector performed independent radiation level surveys of

'3;! ,Q A selected areas and, compared them with licensee survey result No violations or oeviations were identifie t Frisking During tours of the plant, the inspector observed the exit of workers j' and movement of materials from the RCA to the clean areas to determine if proper frisking was performed by workers and proper i fixed and transferable contamination surveys were being performed on  ;

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e f During tours of the facility, the inspector observed the use of survey instruments by radiation control personnel. The inspector l

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examined calibration stickers on radiation protection instruments in use and at various storage locations. Instrument use appeared to be

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No violations or deviations were identifie Caution,- Sin". Labels and Controls l

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10 CFR 20.203(f) requires that each container of licensed-radioactive l

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material bear a durable, clearly visible label identifying the ;

contents Wn quantities of radioactive material exceeded those' '

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, specified in Appendix C. During plant tours, the inspector verified l

' that containers of radioactive material were labeled as required and that proper controls were establishe No violations or deviations were identifie . Facilities and Equipment (83727)

FSAR Chapters 1 and .12 specified plant layout and radiation protection I facilities and equipmen During plant tours, the . inspector observed traffic patterns' in the Units 1 and 2 Reactor Buildings, Turbine Building'

and Control Building. The inspector also observed the use of temporary ;

shielding in plant areas which was used to limit the general ' area dose 1 rates.. Plant housekeeping appeared good and the inspector observed the licensee's labor force performing cleaning operations in the operating, buildings. The inspector also observed the use of ventilated enclosures 4 to limit airborne radioactivit No violations or deviations were' identifie . MaintainingOccupationalExposuresALARA(83728)

10 CFR 20.1(c) specified that licensees should implement programs to keep l workers' doses as low as reasonably achievable. The recommended elements {

of an ALARA program were contained in Regulatory Guide 8.8, Information !

Relevant to Ensuring that Occupational Exposure at Nuclear Power Station's j will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for ;

Maintaining Occupational Exposures ALAR !

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The inspectors discussed the ALMA gvis and objectives with licensee !

representatives and were informt * that the 1987 goal for collective j

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exposure. is 1,700 person-rem. As of ougust 15, 1987, the station had -

accumulated 1,170 person-re A review of open item 50-325/85-39-01 consisting of eleven action ites to reduce collective exposure and enhance the licensee's ALARA program was performe Measurable progress ,

was noted in eight of the eleven items, however, three items require continued management and supervisory attention. The items which still need attention and their current status are as follows. (1) Expand and implement a Maintenance Rework Tracking Progra The ALARA group has received only 6 maintenance rework item tracking sheets since tracking ;

started. It was noted by the inspector that the station maintenance /ALARA i l

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group could utilize the Nuclear Plant Reliability Data System to monitor components / systems requiring rework and the resultant possible unnecessary exposur (2) Implement a positive control program such as use of radiation safety violations to bring attention to unapproved actions which contribute to unnecessary collective exposure. A review of approximately 25 RSVs showed that a majority of the violations reported described events that were minor in nature and would not result in substantive program changes if permanently corrected. I ', Document tailgate meetings which include ALARA discussions. These ituus collectively will be an inspector followup item and will be reviewed during future inspections (50-324, 325/87-28-02).

No violations or deviations were identifie . Transportation of Radioactive Material (86721)  ; Procedures The inspector reviewed licensee procedures and verified that procedures were available for selection of packaging; preparation of waste for shipment; maintenance of packaging; marking, labeling and placarding; nonitoring for radiation and contamination and disposal site acceptance criteria. The licensee indir.ated that the primary procedure used for Gipping, E&RC-0150, Shipment of Radioactive Material, Volume VIII, REv. 020, dated June 8, 1987, was being revised and divided into several different procedures to facilitate its use and implementatio No violations or deviations were identifie Shipment Manifests 10 CFR 71.5 required the licensee to prepare shipments of radioactive material in accordance with Department of Transportation (DOT)

regulations in 49 CFR Parts 170 through 18 The inspector observed the preparation of Shipment #87-159 of three liners shipped in a TN8L shipping cask. The liners contained irradiated reactor core components including control rod blades, local power range monitors and filter housings. The radiation and contamination level surveys, shipment preparation and accompanying paperwork appeared adequat The inspector also reviewed other radioactive waste manifests and miscellaneous shipment manifests for the second quarter of 1987. The paperwork was being completed and maintained as require No violations or deviations were identifie ___-

10 Updating Procedure The inspector discussed the licensee's method for the updating of procedures when regulations changed or additional guidance was provided in IE Information Notices. Licensee representatives stated that _ an ' updating service was used to ensure that the most recent guidance available was incorporated into procedures. The licensee also indicated that personnel at the Harris Energy and Environmental Center informed them of applicable changes to the regulation Licensee representatives further stated that when regulations change, the Quality Assurance group onsite performed a surveillance to ensure compliance on the effective date of the chang No violations or deviations were identifie . Licensee Audits (83724, 83725, 726,83727,84722,and86727)

Licensee TS 6.1.3.4 requires that periodic audits of plant activities be performe The licensee performed a multilevel series of audits in the health physics area by the health physics staff, the onsite Quality Assurance group and corporate health physics section personrie The inspector reviewed the results of the most recent audits performed by the Quality Assurance group in the areas of Plant Activities, Shipping of Radioactive Material, and General Radiation Control Practice The inspector noted that appropriate corrective actions and reviews were indicate The inspector also reviewed the results of the most recent audits performed by the corporate health physics section. The areas assessed were the contamination control program, personnel dosimetry, HP instrumentation, radioactive waste and shipping and plant surveys and surveillance. The inspector noted that appropriate corrective actions and reviews were indicate No vici.tions or deviations were identifie ;1spector Followup Items (92701)

(Closed) Inspector Followup Item 50-324, 325/85-39-01. This item dealt with the upgrade of the plant ALARA program to reduce external exposure The licensee had instituted several improvements to the ALARA program I

based on this inspection item (see Paragraph 10 for details)..

1 Radiological Controls for Drywell During Spent Fuel Movement (TI 2500/23)

l During certain spent fuel handling operations, high transient gamma dose rates can exist in BWR drywell areas due to a lack of design shielding.

l This situation requires the licensee to control access to the drywell 1 l 1

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during fuel movements and place administrative controls on the movem66ts of peripheral spent fuel bundles to preclude excessive radiationil exposure },

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The inspector verified that the licensee had received the General Electric generic communications on this subject and had taken action in response to these notices. During spent fuel movements, drywell access is limited to-areas at or below the 38-foot (38') elevation; no access is allowed above this elevation in the drywell. The biological shield extends up td%the 77' drywell elevation. Drywell access is controlled by RWP and continuous health physics coverage is provided during spent fuel handling operation Pre-job briefings are given prior to starting work which explain the hazards of the work, the control measures to be enforced and the evacuation route to take, if neede Also, no work may be performed in the drywell unless one local drywell radiation monitor is in operation and work above the biological shield is not allowed during spent fuel movement unless specifically approved by the Health Physics foreman. Telephone-communications are available and maintained between the refueling floor, the control room and the HP drywell control poin A portable fuel-chute shield (cattle chute) is also used for all spent fuel movemen The chute is designed to cover the area between the reactor vessel flange and the fuel pool gate which leads into the spent fuel pool. The chute is installed to prevent fuel from dropping through the annulus ring between the core and the reactor pressure vessel wal If fuel were to inadvertently drop in the chute or pass too close to the vessel wall, a radiation monitor would alarm and workers would be warned and evacuate This would be accomplished by sounding an air horn located at the HP control point to the drywel The procedure which addresses fuel movement does not specify a distance (in feet) that the fuel must remain away from the vessel wall. However, the procedure requires the fuel to be pulled straight out of the core and to be moved directly to the cattle chut This ensures that the spent fuel remains approximately 3 feet or more from the vessel wall at all time No violations or deviations were identifie :

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