IR 05000324/1989025
| ML19351A284 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/29/1989 |
| From: | Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19351A283 | List: |
| References | |
| 50-324-89-25, 50-325-89-12, NUDOCS 8910190207 | |
| Download: ML19351A284 (7) | |
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't UNITED STATES
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E NUCLEAR REGULATORY COMMISSION
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REGION il-
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101 MARIEUA ST., N.W.
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ATLANTA. GEORGIA 30323 e,,,,
SEP 2 9 1999 Report Nos.: 50-325/89-25 and 50-324/89-25
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Licensee: Carolina Power and Light Company P. 0 Box 1551 Raleigh, NC 27602 p.
Docket Nos.: 50-325 and 50-324 License Nos.:
DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2
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Inspection Cond c e.
A ut 1-25, 1989 Inspector:
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or i Date Signed Approved by:
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h Y P. Potter, Chief Date 61gned Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY
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Scope:
This was a routine, unannounced inspection to review the status of licensee L
preparations for: an' imminent recirculation piping replacement outage and
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followup on previous inspector identified items from a special ALARA team
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assessment.
Results:
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The inspection occurred three weeks prior to a scheduled shutdown of Unit 2 for replacement of riser and safe end piping with intergranular stress corrosion j
cracking ' (IGSCC).
Based on the inspector's review of' planning documents, a j
. preliminary schedule, and interviews with licensee management and supervision, i
the inspector determined that licensee preparations were not going to be
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complete prior to.the start date for the outage.
Late identification of the
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l piping replacement to the site and late selection of a vendor were factors for
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consideration for the status of preparations.
The inspector's review of-i
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licensee progress for resolving ALARA program problems previously identified during the ALARA team assessment revealed that management's accountability and management of collective dose had improved, but there had been little progress on a number of chronic problems affecting the ALARA program.
Some problems dated back.to 1985.
The need for improved licensee performance in this area was discussed in detail at the inspector's exit.
No violations or deviations were identified.
8910190207 890929 PDR ADOCK 05000324 Q
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' Persons Contacted
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Licensee Employees i;
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- C, Blacknen, Acting Plant Manager
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- A. Cheatham, Manager, Environmental and Radichgical Control (E&RC)
- J. Given, Corporate Quality Assurance t
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. A. Harris, Senior Specialist, Regulatory Compliance
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- W. Hatcher, Supervisor, Security
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- R. Helme, Manager, Technical Support L
- J. Henderson, Supervisor, E&RC i
- J. Holder, Manager, Outage Management
- J. McKee, Supervisor, Quality Control L
- W. Hurray, Project Specialist, Licensing
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- J. O'Sullivan,. Manager, Training
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- G.- Peeler Director, Planning and Scheduling
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- R. Poulk, Project Specialist, Regulatcry Compliance
- R. Queener, Supervisor, E&RC
- R. Smith, Outage Coordinator E&RC
- J. Terry, ALARA Coordinator, E&RC
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~*L. Tripp, Supervisor, E&RC
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- R. Warden, Manager, Maintenance
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Other licensee employees contacted during this inspection included craftsmen, engineers, technicians, and administrative personnel.
Nuclear Regulatory Commission
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- W. Ruland, Senior Resident Inspector
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- E. Tourigny, Project Manager, Nuclear Reactor Regulation
- Attended exit interview i
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Occupational Exposure (83750)
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Outage Preparations The licensee is scheduled to shutdown Unit 2 for 22 weeks starting on September 7,1989, for refueling and to replace recirculation risers and safe-ends in the recirculation piping system.
The piping has a history of intergranular stress corrosion cracking and over the years temporary repairs of weld overlays have been a significant contributor to the station's annual collective dose.
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In discussions with the inspector, licensee representatives in health L
physics (HP) stated that the pipe replacement project was not
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identified for inclusion into the work scope for the Unit 2 refueling
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They also stated that a vendor for the project was not selected until early b
August and was not expected to mobilize to-the station until late
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i August.
This has severely impacted the planning effort since
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p normally, for large projects such as a BWR pipe replacement, a vendor is on site 12 to 15 months prior to reactor shutdown to interface
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with licensee persor.nel in planning for the outage.
In reviewing the status of modifications to be included in the outage the inspector determined that of the 61 design changes / modifications to be performed during the outage, 30 have been approved and issued, 20 are in the approval circuit and 11 have not been released from the
design department for reviews.
In addition, the licensee plans to p(erform work on approximately 2,000 corrective maintenance items trouble tickets) during the outage.
The outage manager stated, L
during an interview with the inspector, that the corrective
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maintenance items are being scheduled on a floating basis and will be worked on a priority basis.
Licensee representatives stated that a schedule detailing the full scope of outage work was not expected to be developed prior to the outage start date.
The inspector noted e
that inadequate time to plan for the outage was significant, in that, in October 1988, an ALARA team assessment reported that recurring less than adequate control of outage duration, and the addition of outage work scope had contributed to Brunswick's high annual l
collective dose.
HP ALARA pipe ~ replacement coordinators stated that to prepare for the possible. pipe replacement, they had representatives from Brunswick visit another BWR during a pipe replacement to gain first hand information on techniques used to reduce dose.
In addition, two contractors with the ALARA group at that facility were employed to provide needed experience for this outage.
HP representatives stated that the NSSS vendor selected to replace piping had just completed a similar project overseas and that the team was still assembled and i
would mobilize to the site as soon as possible.
The inspector reviewed a draft ALARA plan for the outage and noted that all
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personnel assigned to perform outage related tasks for the pipe I
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replacement would first have to perform the same tasks satisfactorily e
on mockups provided by the NSSS vendor, prior to performing the operation in plant.
HP ALARA representatives stated that the preliminary collective dose goal for the 22 week outage was 1350 person-rem and this was a challenging goal since a dose intensive welding procedure would be used.
A special bi-raetallic weld will require inconel buttering on all risers and the anticipated dose is expected to be double that of the process normally used on the riser welds. The inspector observed that HP ALARA outage planning and preparations were progressing satisfactorily with the limited amount of information available.
HP plans to augment radiological support for the refueling / pipe replacement outage with 85 contract HP technicians.
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Inspector Followup Items (92701/83728)
The following inspector followup items (IFIs) were previously identified to the licensee during an ALARA team assessment conducted in October 1988.
The IFIs' focused on weaknesses in the ALARA program and were discussed in
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(0 pen)50-325/88-33-01:
Increased management support and involvement
.is needed in the' ALARA program.
The assessment team found that from 1983 through 1987, the station collective dose was consistently under the annual collective dose goal; therefore, the station annual goals were not challenging, as was intended.
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the inspector determined that management's support for the station
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ALARA program has improved.
An ALARA Review Committee has been established to support the ALARA Comittee.
The assessment team found that the ALARA Comittee did not have management as members,
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and consequently had difficulty in gaining visibility / support for
some ALARA improvements items.
The inspector noted that department annual exposure goals are now more challenging and are being met by most departments,. but additional time is needed to evaluate this i
area. This item will remain open.
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(0 pen) 50-325/88-33-02:
Contractors are not held accountable for
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dose expended on specific tasks.
The ALARA assessment team, had observed at other utilities, that contractors frequently expended
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more dose for. tasks that had previously been performed by the
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licensee.
Successes in dose reduction were observed when contractors were held accountable for dose goals on jobs with a known scope of
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work.
The inspector noted that a dose goal was included in the
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request for quotes for the pipe replacement project, but had been deleted prior to ti;e contract signing.
This is directly opposed to i
the CP&L Exposure Reduction Plan and the station commitment to
support this program.
Licensee representatives informed the
' inspector that this item would be considered for-contract amendment.
This item will remain open, c.
(0 pen) 50-325/88-33-03:
The number of personnel with measurable dose is consistently higher than the industry norm.
The licensee is performing a study to review the scope and size of the work force with the intent of reducing the number of people with
measurable dose, and in relation to its overall effect on the ALARA
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program.
The target date for completion is December 18, 1989.
This
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item will remain open.
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(0 pen) 50-325/88-33-04:
The audit program is not resulting in ALARA program improvements.
The ALARA team reviewed audits of the E&RC program for the years 1983 through 1987 and found that only one audit addressed the ALARA program.
This audit did not result in any
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findings or recommendations. The inspector found in general that the
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audits were not in sufficient depth and did not result in identifying
-radiological technical issues for correction, and ALARA program improvement.
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An inspection report in February 1988 reported that ten audits of the
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E&RC program performed in 1986 and 1987 did not result in any F
radiological deficiencies, or corrective actions designed to improve
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the E&RC program.
In late 1987 the corporate group performing the L<
audits was disbanded as a result of a corporate reorganization.
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new audit program was developed in 1988 that utilized HP technical
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specialists to augment the corporate quality assurance team.
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Radiation Protection and Control Manual was revised (Rev.15) to further define the HP assessment program.
The inspector reviewed the first audit conducted since CP&L took
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action to improve the effectiveness of the audit process.
Ten man-days were spent in preparation for the audit.
One hundred-seventy man-hours over five days were spent in observing work practices and interviews in the protected area.
The audit team consisted of a lead auditor from corporat'e and four HP specialists from other plants in the utility.
The audit reviewed all areas of the E&RC program and resulted in one comment.
It identified that an
ALARA problem report from 1984 identified an. item for potential person-rems savings and it had not been closed. One finding from the audit report found that non-fire retardant wood was observed inside the protected area.
The finding was later addressed by station management.
The limited self-identification program remains as a
recurring problem.
The ' inspector discussed this item with the Manager, Brunswick Nuclear Project and he indicated that improvements would be made in this area.
This item remains open, e.
(0 pen) 50-325/88-33-05: A mechanism should be established to require additional ALARA reviews prior to exceeding dose projections.
The licensee reported that the ALARA staff monitors job dose L
projections daily to ensure early identification of problems and develops corrective actions needed to stop work.
The licensee also
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reported that plant supervision has been successful in effecting necessary changes to improve ALARA performance without the need to stop any project.
This item will remain optn and will be reviewed during the pipe replacement.
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(Closed) 50-325/88-33-06:
The ALARA subcommittee meetings have not been well attended by members or management.
The inspector reviewed attendance of the ALARA committee's meetings (formerly the ALARA subcommittee) and noted that attendance was satisfactory.
This item is close >
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(0 pen) 50-325/88-33-07:
Dose resulting from rework has not been adequately identified and tracked. This was documented as a followup l
item in January 1986.
Based on interviews with plant personnel,
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rework was a significant contributor to the facilities annual dose.
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The item has been reported in two subsequent inspection reports.
A rework tracking system was developed in 1988 but the inspector's
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review of items identified showed that little or no progress has been made.
Plant departments have, over the past two years, notified HP of only six jobs when rework was performed.
Of those six jobs, the inspector noted that five jobs did not incur any dose and one job had 60 mrem.
Rework dose tracking appears to be a chronic problem since i
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recent outage reports also document dose lost to rework, however, the data is not quantitative. This item remains open,
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(0 pen) 50-325/88-33-08: The estimates of man-hours needed to perform j
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a job are frequently overestimated' and result in discrepancies between. estimates and actual man-hours worked.
The licensee has j
developed and implemented an Automated Maintenance Management System i
(AMMS), as a computerized data base for controlling and tracking j
l maintenance work activities.
Plans are to use this system for future j
job planning and job estimates.
This item is due for completion by
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the licensee on September 19, 1989.
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u The inspector noted that this item was identified in December 1985 l
and is a chronic problem that appears to contribute to Brunswick's t
high annual dose estimates.
The inspector discussed this issue with
licensee representatives at length.
HP ALARA coordinators stated that i
dose estimates for jobs to be worked are not subneitted using hours
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estimated to be spent in the radiation area.
Also, frequently job
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man-hours are based on trouble ticket man-hours and have to be
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reduced by HP by a factor of up to eight.
The inspector informed
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licensee management that to wait for the AMMS to be developed to facilitate improved man-hours estimates would not be timely.
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item has been a recurring problem and will remain open.
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(Closed) 50-325/88-33-09:
A significant amount of dose is
i accumulated under general radiation work permits and therefore does not undergo a specific ALARA review.
The licensee has performed ALARA reviews for general radiation work i
permits and required the increased use of special radiation work
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permits. Their actions have significantly reduced the number of jobs j
that were not reviewed for dose saving techniques.
This item is
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closed.
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Exit Interview
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The inspection scope and results were summarized on August 25, 1989, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in specific detail ALARA program weaknesses identified in previous inspection findings.
The inspector informed
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' Licensee management acknowledged that they understood that the NRC is looking for licensee progress in resolving chronic ALARA IFIs.
The licensee did not identify any of the materials provided to or reviewed by the inspector during the inspection as proprietary.
The licensee was informed of the status of items discussed in Paragraph 3.
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