IR 05000324/1988033
| ML14191B060 | |
| Person / Time | |
|---|---|
| Site: | Brunswick, Robinson, 05000000 |
| Issue date: | 01/11/1989 |
| From: | Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14191B055 | List: |
| References | |
| 50-324-88-33, 50-325-88-33, NUDOCS 8901260205 | |
| Download: ML14191B060 (23) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., ATLANTA, GEORGIA 30323 JAN i2 00 ENCLOSURE 3 Report Nos.:
50-325/88-33, 50-324/88-33 Licensee:
Carolina Power and Light Company P. 0. Box 1551 Raleigh,,NC 27602 Docket Nos.:
50-325, 50-324 License No DPR-71, DPR-62 Facility Name:
Brunswick Inspection Conducted:
September 19-23, 1988 Team Leader: 4L/
T. jR. Collins Datd Signed Team.Members: C. H. Bassett R. B. Shortridge Accompanying Personnel: C. M. Hosey Approved by:
CAll C. M. Ho~soy SectionIChief Da e Signed Division of Radiatioh Safety and Safeguards SUMMARY Scope:
This was a special, announced assessment in the area of the licensee's program to maintain occupational exposures as low as reasonably achievable (ALARA).
Results:
The licensee currently has in place most of the elements required for an adequate ALARA progra Program strengths, noted during the inspection, included source term reduction efforts, good general radiation worker knowledge of ALARA concepts, and including exposure goal performance as a part of all plant managements'
annual performance appraisa However, increased support and involvement of management is required if the program is to be fully successful. Weaknesses were also identified in the ALARA program that should be addressed to ensure that the collective annual personnel radiation dose is reduced to the maximum extent possible. These weaknesses were as follows:
-
Management direction in achieving established goals, Paragraphs and Establishing challenging annual exposure goals, Paragraph Total number of personnel onsite with measurable exposure, Paragraph PDR ADOCK 05000261 PNU
-
Effectiveness of the audit program, Paragraph Effectiveness of the ALARA Sub-Committee, Paragraph Personnel exposures received resulting from rework, Paragraph Man-hour estimation for each job, Paragraph Dose acquired under general RWP's that does not receive specific ALARA review, Paragraph Within the areas inspected, no violations or deviations were identifie REPORT DETAILS 1. Persons Contacted Licensee Employees B. Altman, Manager, Maintenance
- A. Cheatham, Manager, Environmental and Radiological Control (E&RC)
B. Cierpiot, Instrument and Control Foreman J. Harness, Plant manager A. Hegler, Operations Supervisor B. Helme, Manager, Technical Support P. Howe, Vice President, Brunswick Nuclear Project D. Hunt,.System Engineer J. Kelly, Construction Coordinator B. Kitchen, Maintenance Supervisor
- R. Mayton, Principal Health Physicist (Corporate)
- B. Meyer, Principal Health Physics Specialist (Corporate)
- R. Morgan, Plant Manager (Robinson)
- A. Poland, Project Specialist,.Radaition Control S * Power, Brunswick Engineering and Support Unit M. Shaw, Operations Shift Foreman
- R. Smith, Manager, Environmental and Radiological Control (Robinson)
- R. Starkey, Vice President, Brunswick Nuclear Project J. Terry, ALARA Coordinator J. Titrington, Operations Principal, Engineer R. Warden, Instrument and Control Supervisor
- B. Webster, Manager, Health Physics (Corporate)
M. Worth, Technical Support Supervisor Other licensee employees contacted included engineers, technicians, maintenance, and office personne Nuclear Regulatory Commission W. Levis, Resident Inspector W. Ruland, Senior Resident Inspector
- Attended exit interview 2. Background (83528/83728)
For the period 1974-1987, Brunswick Units 1 and 2 have exceeded the national average in collective 'dose for Boiling Wate-r Reactors (BWRs)
out of 12 years. The average collective dose for all BWRs for this period is 829 person-rens per reactor over 312 plant-years of operatio Four BWR units had cumulative average exposures which exceeded the BWR cumulative average exposure by 50 or mor Brunswick Units 1 and 2 ranked third on the list with an average exposure of 1340 person-re In 1980, Carolina Power and Light (CP&L) formally implemented their ALARA Progra Procedures were developed at Brunswick incorporating all elements of ALARA in-plant operation In 1983, a person-rem budgeting procedure was issued which established methods for developing plant exposure budgets and General Employee Training (GET)
was upgraded to emphasize ALARA concept Also Brunswick chose to perform weld overlays for piping that was cracking due to intergranular stress corrosion instead of replacing the piping. Weld overlays, intergranular stress corrosion cracking (IGSCC),
non-destructive testing and weld crown reduction have been (and continue to be) major contributors to collective exposure at the statio In 1985, a task force comprised of CP&L personnel was formed to propose a Radiation Exposure Reduction Progra The goal of the program was to lower personnel dose at CP&L facilities to within industry standards. The key elements of the program were to improve supervisor responsibility and accountability in radiation safety, personnel dose reduction; and radwaste volume reductio Increased emphasis was placed on exposure accountability in 198 For 1987, each unit (department) was charged with the responsibility for their dose goal Unit goals for 1987 were approved by unit managers and submitted to the ALARA coordination group. An annual collective dose goal for 1987 was established at 1,700 person-re Later that year Brunswick experienced a refueling outage for Unit 1 which lasted 20 day The refueling portion of the outage was completed with the lowest person-rem (46)
of any previous refueling. effort; however, 1,118 person-rem were expended during the overall outag The major contributor to the collective dose during the outage was weld overlay work (212.5).
In addition, 27 person-rem was due to added work from 13 projects that were not identified during outage planning or were not in the original scope. of work for the outage. A factor which allowed Brunswick to reduce exposure for this outage from what it might have been, was the chemical decontamination of the reactor recirculation piping. The decontamination cost 28 person-rem to perform but saved a postulated 864 person-re The annual collective dose goal for 1988 was set at 1540 person-re Unit 2 refueling outage was completed on April 28, 1988, with the expenditure of 1016.7 person-rem, 109.5 above the goal of 852 person-re In addition, 55.2 person-rem were expended on additional work not included in outage planning. The major contributors.to dose for this outage were Mechanical Stress Improvement Process (MSIP)
work, weld overlays, ISGCC, and Non-Destructive Examinations (NDE). Although recommended by health physics (HP),
a dilute chemical decontamination of the recirculation piping system was not performed to reduce exposure during the outag Table 1 shows a comparison of Brunswick collective annual dose with that of average BWR collective annual dos TABLE 1 Comparison of Brunswick's Annual Collective Dose with the Average Collective Dose for Commercial Boiling Water Reactor BWR Average Brunswick's Dose per Dose Per Year Reactor (Rem)
Reactor (Rem)
1976 549 326 1977 828 1,119 1978 604 1,004 1979 733 1,302 1980 1,136 1,935 1981 980 1,319 1982 940 1,396 1983 1,056 1,738 1984 1,003 1,630 1985 735 1,402 1986 875 955 1987 521 709 3. Program To Maintain Radiation Exposures ALARA (83528/83728)
The following procedures, which implement the station ALARA program, were reviewed by the inspectors:
AI-52 ALARA Subcommittee Activities and Responsibilities AI-53 ALARA Project Evaluation BSP-8 Brunswick Nuclear Project Radiation Exposure Budgeting BSP-30 ALARA Suggestion Awareness Program E&RC-0230 Issue and Use of Radiation Work Permit E&RC-4100 ALARA Program E&RC-410 ALARA Review of Plant Modifications E&RC-410 ALARA Review of Plant Procedures E&RC-410 ALARA Problem Reports E&RC-4150 Use of Temporary Shielding for Personnel Exposure Reducti on Organization The licensee's ALARA organization consisted of a permanent staff of an ALARA project specialist, reporting to the Manager of Environmental and Radiological Control,two senior ALARA Specialists, one ALARA Specialist, and one ALARA technicia The inspectors reviewed the staff members' experience level and qualifications and determined thatthey met the technician qualification requirements of ANSI 3.1 and that each person had extensive applied HP experienc The licensee established an ALARA Subcommittee in 1981 as a standing subcommittee of the Plant Nuclear Safety Committee (PNSC).
The primary function of the ALARA Subcommittee was.to act as an advisory group on plant ALARA related topics to the PNSC, and to identify opportunities to reduce personnel dose. The membership evolved from 13 members in 1983 to 16 members in 1988, that included a chairman, secretary, and 14 members from major station department The committee routinely meets monthly to review and discuss plant ALARA related topics. The inspectors noted that with the exception of the chairman, vice chairman and secretary that new ALARA subcommittee members are appointed annuall The inspectors determined the following based on a review of ALARA Subcommittee meeting minutes (1983-1987) and discussions with licensee representatives:
o The current status of collective dose was discussed at the meetings but not to the extent that would result in concerns and recommendations necessary for the PNSC to become involved in reducing collective dos o Other than HP, managers of station departments rarely attended ALARA subcommittee meeting o ALARA subcommittee members were working level personnel by design (to better address dose reduction in detail), but could not make commitments for the departments they represente o ALARA Problem Report Items are frequently carried for periods of up to six year The inspectors concluded that the effectiveness of the ALARA Subcommittee could be improved by direct participation and support by plant management and supervisio b. Work Reviews Licensee procedure, AI-53, ALARA Project Evaluation, Revision 0, dated April 28, 1987, required a pre-job review to be completed when the initial exposure for the work activity under consideration was estimated to be equal to or greater than one person-re The procedure required that the pre-job review be reviewed and signed by the person responsible for the job, by his foreman or coordinator, by the appropriate system engineer and by an (E&RC) ALARA Specialist or his designe Those activities that were projected to have an exposure estimate equal to or greater than ten person-rem were required to be reviewed and signed by the responsible person's subunit supervisor as wel For jobs with an estimated exposure equal to or greater than 25 person-rem, a further review and signature was required by the unit manager whose originator planned the work and initiated the pre-job revie The means used to determine what level of review was required was the ALARA Project Review for The job originator completed the form indicating the estimated number of man-hours required to complete the work as well as the work location and a description of the work to be performed. The form was then reviewed by an ALARA Specialist who estimated the person-rem to be expended, checked the historical file to determine what person-rem had been expended in the past on similar jobs, and developed an exposure goal for the job.. Following!
completion of these estimates, the appropriate level of review was determined and the reviews and signatures would be obtained as require Procedure AI-53 also required a post-job review of all projects or activities which required the completion of a pre-job revie The post-job review consisted of holding a meeting to critique the job and the exposure expended. Those required to attend included, at a minimum, the individual responsible for the work and an ALARA Specialis Any information or recommendations that would aid in future projects were to be documented in the Post-job Review section of the ALARA Project Review for Those jobs with, actual exposures equal to or greater than 10 person-rem or less than 10 person-rem but exceeding the goal. by 2 person-rem were required to be reviewed and signed by the subunit supervisor. Projects with actual exposures equal to or greater than 25 person-rem or greater than 10 person-rem but deviating from the original goal by plus or minus 25 percent were required to be reviewed and signed by the unit manager as well as the ALARA Subcommittee Chairma From the post-job reviews, the ALARA group compiled job history files for major jobs as well as for unusual jobs which required the expenditure of a significant amount of dos The inspectors reviewed selected ALARA Project Review forms containing pre-job and post-job reviews performed during 1987 and 1988, and verified that the required information concerning man-hours, person-rem and problems or recommendations noted.during the jobs were documented. The required reviews had been performe The inspector determined that lessons learned during previous jobs of a similar nature were reviewed and considered during the ALARA review of jobs being planned for the futur It was also determined that, during 1987, 84% of the station's dose had undergone review and was expended during work that had been preplanne During the review of the ALARA Project Review forms, it was also noted that, in two-thirds of the forms reviewed, the total number of actual man-hours worked, the total number of actual per.son-rem received or both varied by more than fifty percent from the estimates that had been established prior to commencement of the respective job The inspectors discussed these discrepancies with representatives of the ALARA group. They indicated that some of the situations in question had involved Jobs in which the scope of work
had changed or were jobs with which the personnel performing the work were not familiar. Because no mechanism existed by procedure, and in order-to retain the original data for comparison, the estimates for man-hours and/or person-rem.had not been changed but had been left as originally state The causes for the differences in the estimates versus the actual totals had been 'outlined in the post-job portion of the review for As stated above, the reasons for the discrepancies were generally listed as changes in job scope or personnel being unfamiliar with the work being performe In further discussions with licensee representatives, it was noted that a major problem was that the man-hour estimates received from the job supervisors were usually too high and included time not spent by the workers in a radiation are In reviewing the causes for differences in the estimates and the actual totals including area dose rates and man-hour estimates, the inspectors determined that the man-hour estimates appeared to be the major contributo The many discrepancies of greater than 50%
between the estimated and the actual man-hours/person-rem indicated that the licensee's method of estimation of such important data needed to be improved and that some method needed to be developed to allow revision of the estimates once they had been established. The licensee acknowledged the need for an improved method and stated that they would reassess the current proces c. Radiation Dose Goals Licensee Procedure BSP-8, Brunswick Nuclear Project Radiation Exposure Budgeting, Revision 2, dated November 29, 1986, described the process used by the licensee to develop and establish goals for the untits and subunits at the facility. The procedure required first and second line supervisors to establish and maintain person-rem goals for their respective work groups/projects. The procedure also required these supervisors to be responsible for exercising good work control and work practices to achieve the goal In practice, each subunit's ALARA Subcommittee representative was used for this task and, in turn, made use of the ALARA group's experience, historical files, and expertise. Within thirty days of the end of the calendar year, each unit manager then compiled the subunits' exposure. goals and developed an overall goal for the next yea The goal was submitted to the Manager, E&RC for revie The procedure required the Manager E&RC, to review the goals or budgets and ensure that all potential exposure was accounted for, to ensure that the estimates or goals were adequate and challenging yet achievable, and to identify ways of possibly reducing exposures and compiling a site goa The final site exposure goal, following any necessary adjustments, was then required to be signed by the facility Vice President and tracked. E&RC reported on the progress of actual versus budgeted exposures by each subuni The subunit managers were required to conduct a. review of actual versus budgeted exposure at the end of each calendar quarter. If the actual versus budgeted exposure total varied by more than 25% for the quarter, the manager was required to submit a report through the chain of command to the facility Vice President identifying the major reasons for the variance and actions taken, if any, to reduce or limit radiation exposure For 1988, the facility's exposure goal had been set at 1540 person-rem based on the original anticipated normal and outage operation The licensee indicated, however, that they would probably not meet the established goal for 1988 based on added work scope. Licensee representatives did anticipate that they would be able to meet their goal for 1989 which had been set at what they felt the approximate national exposure average for BWRs would be for that year. Also, based on the future anticipated work load, the licensee was projecting that they would be able to continue to meet the BWR national average thereafter except during those years when a double refueling outage occurre d. Management of. Collective Dose The inspectors interviewed supervisors and managers to determine the methods used to manage dose reductio Based on those reviews, the inspectors determined the primary method used was to review dose reports issued by the ALARA grou The inspectors reviewed the weekly, monthly, and quarterly ALARA dose reports used by managemen The dose information contained in the weekly and monthly reports did not appear to contain sufficient detail to inform a manager or supervisor of their performance against a goa Based on those reviews, the inspectors determined that the dose information contained in the weekly and monthly reports were not in enough detail to inform a manager or supervisor of their performance against a goa The quarterly report did contain sufficient information for goal tracking but was not timely to allow managers and supervisors to manager dose on a daily/weekly basi In comparing the various units' weekly and monthly dose expenditures versus dose projections, it appeared that management made no mid course corrections to attempt to bring expended dose back in line with the projected dose once the projection had been exceede During the ALARA program assessment, the inspector did not observe or review any management initiatives or directions to.recover from being over the dose projection It appeared that, although the ALARA group was concerned about collective, dose, there was little concern among managers about being over dose "budget."
One reason for this was the fact that some units were always under budget and that would balance the station's overall expended dose with the dose goa A review of the station's. annual collective dose goals and performance against those goals, as shown in Table 2, demonstrated
that the site collective doses were generally-below the established annual goal Following a review for the work.performed and the station's performance, it appeared that the station's goals were not always challenging and the site. goal was substanitally above the national average for BWR TABLE 2 Brunswick Performance Against Established Dose Goals
84
86
Annual Collective Site Exposure Goal 5,600 3,660 2,500 2,000 1,700 Annual Collective Site Exposure 3,475 3,260 2,804 1,909 1,419 National Average for BWRs 2,112 2,006 1,470 1,750 1,042 The inspectors discussed with licensee management representatives whethe-r or not contractors were held accountable for achieving established dose goal The inspectors were informed that specific contractors were not held accountable for person-rem expended on assigned tasks. The inspectors stated that contractors should be held accountable for doses received since contractor dose is a major contributing factor toward the annual total collective dos Modifying the program to make contractors accountable for achieving dose goals should be benefical in reducing the station's annual dose e. Job History Files The inspectors discussed with licensee representatives the historical data maintained for review when planning radiological work. Prior to 1984, the licensee maintained a log book of ALARA numbers assigned to specific jobs with estimated exposure greater than one person-re The dose was tracked by ALARA number on the specified project In 1984, the licensee initiated a system of maintaining folders on each project with. estimated exposure greater than one person-re In 1987, the Procedure AI-53, ALARA Project Evaluation, was approved which required the use of the ALARA Project Review for The form, as noted previously, included the pre-job and post-job review documentation as well as documentation of estimated and actual person-rem and man-hours, problems encountered during the job and notes from meetings held and lists of attendee These data, along with other notes concerning the specific job and related information, were placed in files in the ALARA group's work are The licensee's computer data base system, Radiological Information Management System (RIMS),
had also been employed to maintain
historical data and provide a means of ALARA revie An ALARA control number was assigned to each job to be tracked and this number was cross referenced with the Radiation Work Permit (RWP)
number assigned to the job.. Using the ALARA review mode of RIMS, a jo originator could enter the ALARA tracking number of a previous project (similar to the one currently being planned)
into the computer. The person would then be provided with information on the previous work including the job location, modification number of trouble ticket number (if used),
the job description and estimated/actual man-hours and person-rem. Other related information could be reviewed by using the RWP review mod The inspectors reviewed selected job history files that were being maintained in the ALARA office. The inspectors noted that the files contained information that would be useful in planning other jobs of a similar nature. The inspector also reviewed the licensee's post outage reports that had been written and issued following the previous nine outages. These had been used to document historical data concerning radiological work. It was noted that the post outage reports were-generally very definitive and identified the problems encountered during the course of the work. The inspector also noted that the majority of the recommendations made by the ALARA group in the post outage reports were included as action items in pre-outage planning. However, no formal program or requirement existed to ensure that the recommendations made by the ALARA group be included in pre-outage planning. The licensee acknowledged this and indicated that they would consider developing a means of formalizing this proces Hold Program Through a review of the procedure outlining the RWP program, E&RC-0230, Issue and Use of Radiation Work Permit, Revision 016, dated June 17, 1988, the inspector noted that specified ALARA reviews were required during the preparation of an RW However, there was no requirement to place any type of a hold or review on the work covered by the RWP when the exposure for the job began to approach or actually exceed the estimated dose projected for the jo The licensee indicated that, although no formal requirement existed in the procedure, jobs were often reviewed when the exposure estimates were approached. This occurred because the ALARA group tracked the exposures daily and the ALARA personnel were aware of those jobs that were approaching or exceeding the estimate Also, notification was often given to the ALARA group by the HP technician covering the work who was aware of the exposure status of the job and was concerned about it. On occasion a concerned worker or supervisor would notify the ALARA group of the exposure status or exposure rates encountered at the work site. The licensee indicated that this was not always a formal review but usually involved at least a review by one of the ALARA Specialist The inspectors also reviewed the function of a committee that' had been established to control. and reduce exposures during outage period In early 1987, an Outage Radiation Exposure Review Committee was established to review any plant modification, project, task or other activity that had an assigned "exposure budget" for which the exposure budget was going to be exceeded according to analysis of the exposure tracking and trends. The Manager, E&RC was to notify the chairman of the committee whenever exposure trending data indicated that an exposure budget would likely be exceeded without corrective action being taken. The chairman would then call a committee meeting to review the project and determine what corrective actions needed to be taken'.
In reviewing. the activity of this committee, the inspector determined that it had met only once since its inception to consider an exposure budget proble Since that time, the Manager, E&RC had handled the exposure problems informally without involving the committee chairman or the committe The Manager, E&RC also indicated that, since the station's expended dose is generally reciewed daily during management meetings, there was little need to convene a committee meetin The licensee acknowledged the lack of.a hold program to. review the status of jobs approaching or exceeding the exposure estimates and the lack of action by the review committe The licensee indicated that a hold program and activation of the review committee would be assessed.and implemented if warrante. Performance (83528/83728)
In discussions with the inspectors, the licensee stated that outage durations, a large number of people with measurable exposure, and work added to outages after the completion of outage planning contributed to the collective dose exceeding the national averag a. Outage Duration and Addition of Outage Scope Both the Outage Manager and Manager of Planning and Scheduling stated in interviews, that the length of outages and the addition of work to outage scope after outage planning was complete were two areas that were contributors to the high annual collective exposur The licensee has taken action to minimize the late addition of design change packages or modification work by setting a deadline prior to an outage. Currently no additional work, except for safety items, will be performed in an outage that is proposed later than six months prior to the outage start date, without the Outage Project Director or Vice President of Brunswick Nuclear projects'approva Planning and scheduling efforts have been increased in the area of carrying forward lessons learned from previous outages. Action items based on previous outage problems were assigned to individuals and progress tracked daily for completion prior to the outage start dat The
Outage Manager stated that outage work has been divided into projects and assigned to unit project managers for the upcoming outag Ninety-six projects will be divided among 10 to 15 unit project managers who will report to a manager for coordination. In addition, the use of mockup training has been increased to improve performance on the job. The licensee stated that the Unit 1 refueling outage, to begin in November 1988, was scheduled for a 10 week duratio Table 3 shows the licensee's program since 1983 for reducing outage duration and person-rem resulting from the late addition of outage scop (The table also shows the person-rem resulting from rework which is dicussed in Paragraph 4.b.)
TABLE 3 Additional Duration Scope Rework Outage Weeks Person-rem Person-rem Unit 1 Condenser/Refueling
150.65 Unit 2 Condenser/Refueling
Unit 1 IGSCC/Weld Overlay
27.18 Unit 2 PT Outage
8.1 Unit 1 Refueling
58 Unquantifiable Unit 1 Refueling
2 Unquantifiable Unit 2 Refueling
5 Unquantifiable b. Unnecessary Dose Resulting From Rework Inspection Report Nos. 50-325/85-39 and 50-324/85-39 dated January 1986, reported that, based on interviews with plant personnel, maintenance rework was a significant contributor to the facilities' external exposur The licensee agreed to evaluate the finding and it was carried as inspector followup item (IFI)
50-325/85-39-0 In a subsequent inspection (Inspection Report Nos. 50-325/87-28 and 50-324/87-28),
the inspector's review of the IFI noted that the licensee had not effectively addressed the IF This inspection carried the IFI as 50-325/87-28-0 The inspectors attempted to quantify the amount of unnecessary exposure due to rework through review of licensee outage reports and through discussions with licensee representatives and managemen However, due to the failure of the licensee to implement a rework tracking program, no quantification of such data could be made. The manager, E&RC stated that his department had attempted to track rework but was not able to identify rework in sufficient detail to do so. The inspectors found that some departments' definition of rework was that any number of repairs or removal/reinstallations may take place on a system, but, these repairs were not considered rework until after the system was tested and further repairs were neede Table 3 shows the amount of dose resulting from rework when it could
be quantifie The inspectors determined that corrective actions sufficient to reduce unnecessary exposure resulting from rework cannot be taken until cooperation is received from all departments in order to identify rework (as defined from an exposure standpoint) and a formal system implemented to track rewor c. Number of Personnel With Measurable Dose The inspectors reviewed the data concerning the number of people with measurable dose at Brunswick for the period 1983 through 1987. In 1983, the ALARA Subcommittee minutes 83-03 reported that Brunswick site.had badged more workers than any other United States.nuclear facility for four consecutive years (since 1979).
NUREG-0713, Volume 7, Occupational Radiation Exposure at Commercial Nuclear power Reactors and Other Facilities 1985, Table 4.7a shows five year total of workers with measurable doses (greater than 100 millirem) for the years 1981 through 1985. Brunswick Unit 2 had 23,516 workers with measurable dose while the next closest total for a BWR was 16,696 for that perio Licensee management stated that the number of people with measurable dose was high and that efforts were in progress to reduce the number of people entering the radiologically controlled are Two work groups were involved in this effor Brunswick Engineering Support Unit, a group that is responsible for engineering modifications, would be moved to Raleigh Corporate Headquarters, and the Brunswick Construction Contractor group would be deleted in March of 198 Licensee progress in reducing the number of people with measurable dose is shown on Table 4 as well as the percent of difference above the industry norm for BWR As can be seen for the years 1983 through 1987, Brunswick had approximately 153% more workers with measurable dose than the industry norm for a typical BW TABLE 4 Comparison of Brunswick with Industry Norms for Average Number of Personnel with Measurable Dose Per Reactor 1983-1984 1985 1986 1987 Number of Personnel with 2,601 2,540 2,025 1,685 1,526 Measurable Dose BWR Industry Average of Personnel 1,287 1,522 1,366 1,264 1,269 with Measurable Dose Percent of Industry Norm 202 166 148 133 120 d. General Radiation Work Permits
Through discussions with licensee representatives, the inspectors determined that the method used to track radiation exposure by means of individual job or task had been revised several time The licensee was continually trying to refine the method of tracking dose in order to better be able to determine where the dose was being expende From these discussions and reviews of previous outage reports, it was determined that this was, in general, the cas However, it was noted that., during the previous three outages and during the outage that was in progress, there was one category where dose.was not tracked in a manner that would facilitate determination of dose expenditure per activity. In these four cases approximately 10% of the total dose expended during the outages had been assigned to "general area" activitie The licensee indicated that these activities included such things as housekeeping, restocking *of protective clothing bins, general area tours and other non-specific activities. Another category that accounted for approximately 10% of the dose used during the outages was "support activities."
The inspectors indicated that this was a significant amount of dose and that this dose was not receiving any type of an ALARA revie The licensee acknowledged this fact and i.ndicated that they would evaluate the impact of this and the need for future revie e. NUREG/CR-4254 The inspectors reviewed NUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power Plants: Study on High Dose Jobs, Radwaste Handling and ALARA Incentives, dated April 1985, with licensee ALARA personne NUREG/CR-4254 contains data on dose experienced throughout the industry for typical high dose job The inspectors compared the licensee's exposure history for several of those jobs described in the NUREG as indicated in the following table:
TABLE 5 Brunsiwick Dose Summary for High Dose Jobs NUREG/
CR-4254 Job Unit
86
88 Avg Snubber Inspection
18
290 and Repair
27
In Service
45
150 Inspection
61
-
CRD, Rebuild
47
60 Replacement
27
Insulation
58
44 Replacement
55
Plant
51
37 Decontamination
41
RHR System
58
34 Repair/Main Reactor
49
24 Assg/Disss.
82
9 Insp./Repair
14
.
Instrumentation
87
15 Repair/Cali TIP/SRM/IRM/PRM
12
11 Calib./Repair/Maint. 2
13 Turbine
-
6
6
The inspectors determined that for most of the jobs reviewed, the licensee's dose performance compared favorably with the industry averages indicated in NUREG/CR-4254 (1974-1984 data).
Dose Reduction Initiatives (83527/83728)
The following dose reduction initiatives performed by the licensee resulted in the following estimated person-rem savings as indicated below:
a. Shielding Temporary Shielding NET Person Year Request (TSR)
REM Savings
1983
35 o
.1984
53 o
1985 144 133 o
1986
159 o
1987
.
87 454 467 Chemical Decontamination o
Unit 2 Reactor Water Cleanup System (RWCU) -
221 Person-Rem Saved in 1984
o Unit 2 Reactor Recirculation System (RRS)
-
1355 Person-Rem Saved in 1986 o
Unit 2 RWCU System -
52 Person-Rem Saved in 1986 o
Unit 1 RRS -
864 Person-Rem Saved in 1987 c. Reduced Turbine Building Operating Surveillance
Reduced Person-Rem by 5 Person-Rem/month d. Control Rod Drives (CRDs)
o Testing of CRDs to eliminate. unnecessary rebuilds reduced person-Rem by 20 Person-Rem/Outage e. Training/Mock-Ups o
Types
-
CRDs, reactor recirc suction. nozzles, jet pump riser bio-shield windows, valves and valve operators o
Estimated Person-Rem Savings Unit 1 1983 Outage -
730 Unit 2 1984 Outage -
Unit 1 1985 Outage -
140 Unit 2 1986 Outage -
Unit 1 1987 Outage -
100 f. Chemistry Controls During the period from 1983 through 1987, the licensee has effectively managed reactor coolant chemistry in both units to keep reactor water conductivity at or below Administrative or Technical Specification limit This program has been partly successful by operating at least one of the Reactor Water Clean-Up pumps during power operations to maintain reactor coolant chemistr Reactor coolant chemistry has not been -a factor in increased collective person-rem exposure during the assessment period of 198.3 through 198 Fuel Integrity During the period from 1983 through 1987, the licensee effectively managed fuel integrity in both units by enhanced chemistry control The licensee implemented a fuel integrity monitoring and chemistry measurement evaluation program which included allowable levels of dose equivalent 1-131 (DEI)
in the Primary Coolant Syste The DEI was monitored on a daily basis, under equilibrium and transient conditions, with respect to the technical specification limit of one microcurie per gram (1 uCi/gm).
This was accomplished by monitoring
daily iodine isotopic concentrations in the primary coolant system, based on measurements performed by station chemists, and calculating the DE During refueling outages, the licensee performed an analysis of each fuel assembly that was suspected of having fuel degradatio After these tests were performed (wet sipping) and the fuel assembly had been determined to be defective, the entire fuel assembly was replaced by a new fuel assembly known not to be defectiv All o the fuel assemblies that were determined to be defective were later reconstituted by replacement of individual fuel pin.
Interviews (83528/83728) Employee Interviews Licensee employees were interviewed to assess their knowledge, involvement, and perspective of the utility's ALARA Progra An ALARA questionnaire was prepared prior to the inspection and was utilized during each interview to ensure that each employee's ALARA awareness and involvement was evaluated uniforml The employee questionnaire was prepared to evaluate the employee's knowledge of ALARA goals, concepts,-policies and procedure documents; individual responsibilities, personal doses and personal dose limits; the employees involvement in special ALARA training, communication with co-workers and supervision, and participation in the ALARA suggestion program; and the employees' perspective on how to improve the ALARA program, what events or conditions have caused increased personnel doses, and what events or conditions had helped reduce personnel dose (1) Employees All employees interviewed entered the RCA on a daily to weekly basis depending on plant condition (2) Knowledge of ALARA Program Each of the employees interviewed was-familiar with the basic ALARA concepts taught in the GET program and knew that they had a basic responsibility for implementing the utility's ALARA program by performing tasks in a manner consistent with the utility's ALARA polic In general the employees knew their current radiation exposure and their exposure limi The employees generally were aware of where the ALARA requirements originated and what documents described the ALARA program objectives. Most of the employees interviewed knew that each of their sections had an ALARA goal, but generally were unaware of the goal that was establishe However, the employees did know
that they could find out these section goals from the ALARA staf (3) ALARA Program Involvement The majority of employees interviewed had not received any ALARA training other than given in the GET cours A majority of those interviewed had received some informational ALARA training on jobs requiring ALARA pre-job planning and on-the-job training. The employees reported frequent discussions of ALARA objectives on major jobs during outages with co-workers and supervisors. The employees also reported good communications with the ALARA and HP staff Only a small fraction of employees interviewed had participated in the formal ALARA suggestion program. Other employees reported that they had made suggestions to supervisors informally. and had not used the formal ALARA suggestion program believing it was only for
"significant ALARA suggestions."
(4) Perspective Most of the employees had suggestions on how the ALARA Program could be improved. The suggestions included better planning and scheduling of work to ensure appropriate equipment and tools were readily available to perform tasks expeditiousl The majority.of employees had opinions on things that had contributed to decreases and increases in personnel exposure Employees believed that the following actions had contributed to exposure reductions:
use of tempbrary shielding, special tools, permanent shielding, chemical decon, flushing of various system components and lines, and decontamination of contaminated areas:
within the RCA. Employees believed *that the following actions had contributed to increases in personnel exposures:
poor maintenance planning and scheduling in the past, weld overlays of recirculation pipe in the drywell, use of unqualified contract personnel, and use of too many personnel onsite entering the RC b. Management Interviews Licensee managers and supervisors were interviewed to assess their knowledge of the utilities' ALARA Progra An ALARA questionnaire for managers and supervisors was prepared prior to the inspection and was utilized during each interview to ensure each manager's and supervisor's ALARA awareness and involvement that was evaluated uniformly. The questionnaire was prepared to evaluate the manager's or supervisor's knowledge of ALARA goals, concepts, policies and procedure documents, individual responsibilities, personal exposure, and personal exposure limits; the manager's or supervisor's involvement in special ALARA training, communication with coworkers and supervision, and participation in the ALARA suggestion program;
and the manager's or supervisor's perspective on how to improve the ALARA program, what events or conditions have caused increased personnel exposures, and what events or conditions has helped reduce personnel radiation exposure (1) Managers and Supervisors All individuals interviewed entered the RCA on a weekly to monthly basis depending on plant condition (2) Knowledge of ALARA Program Each of the individuals interviewed was familiar with the basic ALARA concepts taught in the GET program and knew that they had a basic responsibility for implementing the utilities ALARA program by performing a task in a manner consistent with the utility's ALARA polic In general, the managers and supervisors interviewed knew what their current radiation exposure was and what the exposure limit was for their department The managers and supervisors had a.good understanding on where the ALARA requirements originated and what corporate and plant documents described the ALARA program objective All of the managers and supervisors interviewed knew what their departments ALARA goals wer (3) ALARA Program Involvement The majority of the managers and supervisors interviewed had not received any ALARA training other than that given in the GET course. Each department had a dedicated individual to serve on the ALARA Sub-Committee, which met on a monthly basis or as appropriate. The ALARA Sub-Committee members represented their departments in discussions of ALARA objectives for major outage job None of the managers or supervisors interviewed had participated in the formal ALARA suggestion progra However, generally most of the managers or supervisors interviewed were aware of. the number of ALARA suggestions submitted by their departments. in the past or current yea These ALARA suggestions were usually submitted by the departments'
Sub-Committee members and not by plant employee (4) Perspective All managers and supervisors interviewed had suggestions on how the ALARA program could be improve The suggestions included better scheduling and planning of work to ensure appropriate equipment and tools were readily available and continue to increase the awareness of the ALARA concept to all levels of plant personnel. These methods could be through GET retraining, departmental training, non-licensed training or through the Advanced Radiation Worker Training (ARWT)
Progra The ARWT
program was in the process of being revised and was to be implemented in the first half of 198 The majority of managers and supervisors had opinions on things that had contributed to decreases and increases in personnel exposure Individual managers and supervisors interviewed believed that the following actions had contributed to exposure reductions:
use of temporary shielding, permanent shielding, reduced work activities in high radiation areas, chemical decon and flushing of various systems components and lines, reduction of contaminated areas within the radiological controlled area, use of reach rods-on specific systems and reducing refueling outage duration Individual managers and supervisors interviewed believed that the following actions had contributed to increases in personnel exposures:
poor maintenance planning and scheduling in-the past, forced outages, weld overlays of recirc pipe inside the drywell, repetitive work or rework of-specific jobs, number of personnel on site entering the RCA, duration of outages, and failure to manage dose on a daily basis to stay within budgeted goal.
Internal Audits and Assessments (83528/83728)
The inspectors reviewed annual audits of the site Radiation Control Program for the years 1983 through 1988. The purpose of the annual audit by Corporate Quality Assurance group was to assess the adequacy and effectiveness of the E&RC program through review, evaluation, and verification of implementation of the Plant Operating Manual, Technical Specifications, Final Safety Analysis Report,. and Corporate Quality Assurance Program. Only one audit addressed the ALARA Program in any detail but did not result in. any comments or recommendation The inspectors found in general that the audits were not in sufficient depth and did not result in identifying radiological, technical issues for correction, for ALARA program improvemen Licensee management representatives acknowledged the inspectors concerns and stated that the audit and assessment program would be reviewed and evaluated to assess the effectiveness of ALARA programmatic problem.
Training (83528/83728)
The inspectors reviewed the licensee's program for ensuring that all employees received training in ALARA beyond that given in basic GET. Both the ALARA group and the site non-licensed training group were involved in giving various types of ALARA trainin The ALARA group provided input for the training given to engineers onsite and provided ALARA-related training as requested for the QA/QC group. The ALARA group also sponsored all types of mock-up training such as in the use of:
1) cutting equipment, welding equipment and QC inspections of highly irradiated
components,, 2) shielding, 3) glove bag/containments, and 4) mock-up training in the maintenance/repair of various valves, snubbers and motor The site non-licensed training organization had been tasked with and had completed including ALARA topics and training into all aspects of the training given by the grou This included the instruction furnished under the Craft and Technical Development Program. The inspector reviewed lesson plans for training offered in radiological control, chemistry, mechanical maintenance, electrical. maintenance, and instrumentation and control activities and verified that ALARA topics/training were mentioned as require The inspectors also toured the licensee's practical factor training area One area was equipped with a mock-up of the underside of the reactor vessel and was used to. train personnel in the proper method to remove a control rod drive mechanism. Another area housed various motors, valves, piping systems, snubbers, and valve operators for training purpose Another training area had been equipped with large sections of piping on which cutting or welding equipment could be set up and operated for training purposes. The inspectors determined that the licensee should be able to provide adequate mock-up and classroom trainin The inspectors also reviewed the status of the licensee's advanced GET III training program with licensee representative This program had been suspended in 1987 for evaluation. A discussion of what the new training program is scheduled to include and when it is scheduled to begin is found in Enclosure 2, Paragraph. Conclusions (83528/83728)
The inspection revealed that the licensee appears to have in place most of the elements of an adequate dose reduction progra However, the licensee's past performance has been less that adequate and the effectiveness of the implementation of the recent initiatives remains to be see In the past, lack of management support and involvement in ALARA, conflicting operational priorities, and unforeseen work items have caused major problems for the ALARA progra Increased licensee management support and involvement will be required to lower the licensee's collective station dose to be consistent with the nationa average for BWRs. The following significant issues were identified during the inspection and should be addressed by the licensee to increase the effectiveness of their ALARA program:
a. Increased management support and involvement is needed in the ALARA Program (Paragraphs 3.c and d) (50-325/88-33-01).
b. Annual exposure goals are not challenging and should be established at or below the industry norm (Paragraph 3.d) (50-325/88-33-02).
c. The number of personnel with measurable exposure is consistently higher than the industry norm (Paragraph 4.c) (50-325/88-33-03).
21 The audit program is not resulting, in ALARA program.improvements (Paragraph 7) (50-325/88-33-04).
e. A mechanism should be established to require additional ALARA reviews prior to exceeding dos projections (Paragraph 3.f)
(50-325/88-33-05).
f. The ALARA Subcommittee meetings have not been well attended by members or management (Paragraph 3.a) (50-325/88-33-06). Exposures resulting from rework has not been adequately indentified and tracked (Paragraph 4.b) (50-325/88-33-07).
h. The process of estimating man-hours needed to perform a job are frequently overestimated and result in discrepancies between estimates-and active man-hour worked (Paragraph 3.b)
(50-325/88-33-08).
i. A significant amount of exposure is accumulated under general radiation work permits and therefore, not recei.ving specific ALARA review (Paragraph 4.d) (50-325/88-33-09).
1 Exit Interview (30703)
The inspection scope and findings were summarized on October 5, 1988, with those persons indicated in Paragraph The inspectors described the areas inspected and discussed in detail the inspection findings (see Paragraph 9).
The licensee acknowledged.the inspection findings and took no exceptions. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during the inspection.