IR 05000324/1990006
| ML20012C526 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/06/1990 |
| From: | Potter J, Shortridge R, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20012C522 | List: |
| References | |
| 50-324-90-06, 50-325-90-06, NUDOCS 9003220155 | |
| Download: ML20012C526 (10) | |
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jkt etrug UNITE 3 STATES -
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.. jo NUCLEA'l RE!ULATORY COMMISSION g.
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i 101 MARIETTA STREET,N.W.
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f ATLANTA, GEORGI A 30323
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WAR 0 81930 Report Nos.: 50-325/90-06 and 50-324/90-06 f
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 Fecility Name: Brunswick I and 2 Inspection Conducted: January 29 - February 2, 1990
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Inspectors:
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R. D. Shorttidge F
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Approved by:
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- 7. M Pottei, Chief igned
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Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch
Division of Radiation Safety and Safeguards
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SUMMARY
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Scope:
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This unannounced-inspection - of radiation protection activities included - a review of the licensee's organization and management controls, external and
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internal exposure controls, dosimetry, as low as reasonably achievable (ALARA)
program, surveys and, control of radioactive material, solid radioactive waste, transportation of radioactive material, and follow-up of previously identified-items.
Results:
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Within the areas reviewed, one violation was identified:
Failure to maintain access to high radiation areas, with intensity greater than 1,000 mrem /hr, as required by 10 CFR 20.203.
The inspectors found the radiation protection program to be adequate; however, a program improvement-item was identified to reduce source term and occupational collective dose at
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the plant.
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k REPORT DETAILS 1.
Persons Contacted Licensee Employees c
I. Barden Instructor, Training Department
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- C. Blackman, Manager, Operations
- S. Callis, Licensing On-site Representative
- A. Cheatham, Manager Environmental and Radiological Controls (EARC)
W. Conn, Foreman, E&RC
- W. Dorman, Manager, Quality Assurance and Quality Control
- S. Hamilton, Senior Project Specialist, E&RC
- J. Harness General Manager
- R. Helme, Manager, Technical Support
- J. Henderson, Manager, Radiological Controls
- J. Holder, Manager, Outage Management and Modifications
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- J. McKee, Manager Quality Assurance
- D. Moore Unit Manager, Engineering
- J. Moyer, Technical Assistant, Plant General Manager
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- C. Roberston, Manager. Enviror, mental and Chemistry
- W. Simpson, Manager, Control ano Admin',stration
- R. Starkey, Manager, Brunswick huclear Project
- J. Terry, ALARA Supervisor, E&:tC
- R. Warden, Manager, Mainteance G. Worley, Radiation Control Foreman-Other licensee employees contacted during this inspection included technicians and office personnel.
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Nuclear Regulatory Commission 1
D. Nelson, Resident Inspector
- W. Ruland, Senior Resident inspector
- Attended exit interview held February 2,1990 p
2.
OrganizationandManagementControls(83724)
i The inspectors reviewed changes made to the licensee's organization, L
staffing levels, and lines of authority as they related to radiation L
protection, and ' verified that the changes had not adversely affected the licensee's ability to control radiation exposures or radioactivity.
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The inspectors discussed with the Radiation Protection Supervisor the type, methods of, and degree of interaction between plant groups. The inspectors reviewed the licensee's program for self-identification of weaknesses related to the radiation protection program and the appropribteness of corrective tction taken.
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I The inspectors discussed the audit and surveillance program related to i
radiation protection, radioactive waste management, and transportation of l
radioactive material with licensee representatives. The inspectors
reviewed the following:
QualityAssuranceSurveillanceReport(0SAR): QSAR 89-10, Follow-up
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of Events at H.B. Robinson QSAR 89-044, Shipment of Spent Nuclear Fuel
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QSAR 89-045, Radiation Work Permits / Radiation Control
QSAR 89-065. Radiological Controls During Unit 2 Outage
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QSAR 89-073, Radiological Controls During Unit 2 Outage
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QSAR 89-081. Unit 2 Outtr,e Mainteance Activities and Fccility
No violations or deviations wr.re identified, f
3.
Training and Qualifications
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10 CFR 19.12 requires the licensee to instruct all individuals working in or frequenting any portion of the rertricted area in the health protection problems associated with exposure to vadioactive material or radiation, in
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precautions or procedures to minimize exposures, and in the purposes and functions of protective devices employed, applicable provisions of Commission Regulations, individual responsibilities, and the availability of radiation exposure data.
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The inspectors reviewed the licensee's lesson plans for Respiratory
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Protection Training. The lesson plans appeared to be adequate in scope and content.
The lesson plans addressed course objectives that included discussions of the purpose of training, licensee programs for respiratory rotection, means for controlling exposures to hazardous materials p(radiological and others), worker's rights, certification requirements,
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human respiratory system, concentration limits, and. regulatory guidance and standards for respiratory protection. The licensee provides three hours of classroom training and 30 minutes of performance training with respiratory protection equipment. In the laboratory portion of the training, the students have the opportunity to inspect, don, wear, and i
remove the respiratory equipment that they may be wearing on the job.
Licensee representatives reported that students were required to notify the training department of the type respirators utilized in their work.
i The licensee does not require each student to try on each type respirator in the laboratory.
However, each worker was required to don the appropriate respirator facepiece for quantitative fit testing, prior to receiving certification to wear the respirator,
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No violations or deviations where identified.
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4.
External Exposure Control and Personnel Dosimetry (83724)
The inspectors reviewed selected radiation work permits (RWPs) for l
appropriateness of the radiation protection requirements based on work scope, location, and conditions. During tours of the plant, the inspectors
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observed the adherence of plant workers to the RWP requirements and discussed the RWP requirements with plant workers at the job site.
10 CFR 20,202 requires each licensee to supply appropriate personnel
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monitoring equipment to specific individuals and require the use of such equipment. During tours of the plant, the inspectors observed workers wearing appropriate personnel monitoring devices.
10 CFR 20.203 specifies the posting, labeling, and control requirements for rediation areas, high radiation areas, airboree radioactivity areas, and radioactive material. Additional requirements for control of high radiation areas are contain2d in Technical Specification (TS) 6.12. During
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tours of the plent, the inspectors reviewed the licensee's posting and control of radiation areas, high radiation areas, cirborne radioactivity areas, contamination areas, radioactive material areas, and the labeling of radioactive mhterial.
TS 6.12.2 requires that each high radiation area, in which the intensity is greater than 1,000 mr/hr. have locked doors to prevent unauthorized entry.
Tne inspector reviewed radiation saf ety violations and Nonconformance Reports related to five separate events where locked high radiation area doors were found open.
The date of the occurrences and locations were as follows:
April 20,1989, Unit 170' Elevation, Turbine Area July 20,1989 Unit 2 77' Elevation Reactor Building. Valve room October 7,1989, Unit 120' Elevation, Turbine Building EHC room January 5, 1990, Unit 1 70' Elevation, Southwest MSR Door January 20,1990, Unit 2 Fuel Pool Heat Exchanger South Door The inspectors noted that an operator and resident inspector making rounds identified the unlocked door for one event.
The other events were identified by health physics (HP) technicians or quality control inspectors.
In all cases the licensee took immediate corrective action to lock these areas upon discovery, and to initiate an investigation to determine the root cause of the event.
In discussions with the inspectors, the manager of Environmental and Radiological Contr01 (E&RC)
stated that investigations showed that several problems contributed to the events.
In one case the design of the locking mechanism for a gate made it appear locked when in fact it was not.
In several cases the locking mechanism was not functioning properly, or the doors / gates were lef t unlocked by personnel.
In addition, high radiation area key controls were such that culpability was difficult to determine.
As a result, the licensee is taking corrective actions to-place more stringent administrative controls on keys to very high radiation areas, to repair the malfunctioning locks, and replace the gate with a lockable door. The inspectors acknowledged that corrective actions had been taken, and were proposed, but had not been completed and that the five events of failure to maintain access to a high radiation area locked were identified as an
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apparent violation of 10 CFR 20.203(c)(iii) and TS 6.12.2 (50-325, 324/90-06-01).
No deviations were identified.
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Internal Exposure Control and Assessment (83725)
10 CFR 20.103(a) establishes the limits for exposure of individuals to concentrations of radioactive materials in air in restricted areas. This section also requires that suitable measurements of concentrations of l
radioactive materials in air be performed to detect and evaluate the
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airborne radioactivity in restricted areas and that appropriate bioassays be performed to detect and assess individual intales of radicactivity.
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10 CFR 20.103(b) requires the licensee to use process or other engineering controls, to the extent prtctical, ta limi'; the concentr6tions of radioactive material in air to imels below that specified in Part 20, Appendix B, Table 1, Column 1. or limit concentrations when averaged over the number of hours in any week dur#,ng which individuals are in the area to less than 25 percent of the specified concentracions.. During plant
tours, the inspectors observed the use of temporary ventilation systems and containment enclosurer. The inspectors discussed the use of this equipment with licensee personnel.
10CFR 20.103(b) requires that when it is impracticable to apply process or engineering controls to limit concentrations of radioactivity material in
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air below 25 percent of the concentrations specified in Appendix B.
Table 1. Column 1 other precautionary measures should be used to maintain the intake of radioactive material, by an individual, within seven consecutive day)s as far below 40 MPC-hours as is reasonably achievable.10 CF L
use of respiratory protection equipment in estimating exposures of individuals to radioactive material in air provided the licensee maintains i
and implements a respiratory protection program that includes, es a l
minimum, written procedures regarding supervision and training of personnel and issuance records.
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The inspectors reviewed licensee procedure E&RC-0220 Respiratory Protection Program, Revision 23, and verified that the procedure was consistent with regulations TSs and good HP practices.
By review of records, observations, and discussions with licensee
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representatives, the inspectors-evaluated the licensee's respiratory l
protection program, including training, medical evaluations, fit-testing, MPC controls, quality of breathing air, and the issue, use, repair, and storage of respirators. The inspectors selected personnel from RWPs requiring respiratory protection and verified that the individuals had received proper general employee and respirator training, received required medical evaluations, base-line whole body counts, and had been properly fit tested with the respirators use.
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The inspectors reviewed the licensee's procedure for sampling breathing air quality and reviewed the records of quarterly breathing air quality analysis. The licensee's procedure required that the breathing air be
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sampled quarterly or whenever maintenance is performed that could effect
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the quality of the air, as determined by the Radiation Control Instrument Foreman. The inspectors determined that the licensee had not defined what maintenance activities would recuire the breathing air to be sampled following maintenance on breathtng air equipment. Additionally, the licensee did not have a requirteent to notify health physics whenever maintebance of the breathing air equipment vould be perfomed. Licensee 7epresentatives were infurrred of the precedure weakness.
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No violations cr devi niors were identiVied.
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6.
Surveys, Monitoring, and Control of Radioactive Ma'.erial (83750)
10 CFR 20,201{b) requires each lic;entee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of r6dioactive hazards that mcy be present, t
The inspectors reviewed selected records of radiation and contamination surveys performed during January and February,1990, and discussed the survey results with licensee representatives.
During tours of the plant, the inspectors observed hP technicians performing radiation and contamination surveys.
The inspectors discussed with the licensee the methods used to release
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material from the restricted area and observed technicians performing release surveys for material.
The inspectors performed independent radiation and loose surface contamination surveys in the Unit 2 Reactor Building and verified that the areas where properly posted.
The inspectors noted, when performing radiation area surveys, that radiation levels existed in passageways that were up to 60 mr/hr. Also, areas outside high radiation areas containing radiation hotspots or heavily shielded components had high readings.
The licensee had posted several areas in each unit as no loitering with the radiation dose rate on the sign.
However, a number of areas with dose rates between 5 mr/hr and 60 mr/hr existed with no information posted to inform personnel.
Licensee representatives indicated that they would evaluate the need for posting additional information on radiation levels in these areas.
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Control of contamination at the source was identified to licensee management as a problem needing attention.
The licensee maintains 414,831 square feet (f tr) as contro11r4ble areas.
Currently 20 percent or 83,951 ft2 of controllable area is contaminated. The inspectors reviewed licensee trending and analysis of personnel contamination events (PCEs) and l
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noted that the licensee documented 652 PCEs (skin and clothing contaminations) in 1989.
Licensee analysis showed that in November 58.1 percent, December 51 percent, and January 37.1 percent of PCEs occurred in c'een areas of the controllable radiological area of the plant. Licensee representatives stated that when the trend for PCEs in clean areas was ob'erved they increased mopping clean areas to twice per shift, and this s
was attributed to the decrease in percentage of PCEs in clean areas in
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January.
During tours of the radiologically controlled area (RCA), the
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inspectors observed in a three day period, several systems leaking water into controlled surface contamination areas with the water then running nut into clean areas. After the pump was locked out to prevent salt water from entering the radwaste system, a contarinated sump overflowed into a
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clean area.
Drip containments and berms were not installed to contain these spills.
In discussions with the manager of' E&RC, the inspectors were told that they would evaluate the problems identified with control of contamination at the source and personnel contaminated in clean areas of the RCA.
No violations or deviations were identified.
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7.
Program for Maintaining Exposures As low As P.easonably Achievable (ALARA)
(83750)
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10 CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures as low as reasonably achievable. The recommended
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elements of an ALARA program are contained in Regulatory Guide 8.8, l
"Information Relevant to Ensuring that Occupational Radiation Exposure at
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Nuclear Power Stations will be ALARA," and Regulatory Guide 8.10
" Operating Philosophy for Maintaining Occupational Radiation Exposures ALARA."
The inspectors reviewed data from the Recirculation Pipe Replacement
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Project (RPRP).
Licensee representatives stated that the overall project was completed in 115 days and incurred 467 person-rem which was above the projection of 463 person-rem and goal of 400 person-rem.
A postulated savings of 452 person-rem was attributed to chemical decontamination of the recirculation systems, shielding the N-2 nozzles, hydroflushing, power brushing, and shielding the inside diameter of the nozzles.
The inspectors noted that most elements of the RPRP were completed near the person-rem estimate, however, several major operations performed by the sub-contractor were significantly overbudget, along with supervision, quality control, and non-destructive testing required for the project.
Collective dose for the site was 1,786 person-rem which was significantly above the goal of 1,150 person-rem for 1989.
The inspectors noted that the refueling outage scheduled for 22 weeks was currently at day 144 on
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January 30, 1989, and was 26 days behind schedule.
In reviewing a statistical summary report on persons onsite with measurable whole body exposure, the data showed that the trend of total persons monitored was declining but the total of people with measurable exposure was increasing, and was the highest since 1985.
In interviews with licensee management,
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l the inspectors were told that the control of outage work scope and the high numbers of people with measurable expor.ure were recognized problems that needed improvement.
The licensee established a person-rem goal of 1,400 for 1990 and stated that they considered the number high but realistic since the Unit 1 RPRP outage that is scheduled for June would be larger in scope than the previous Unit 2 outage.
The inspectors noted that plans and initial efforts had been taken by corporate health physics to cevelop, obtain approval for, and implement a
comprehensive tource term reduction program.
The need for this program
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and a more concerted effort and program to reduce collective dose was identified by the inspectors as a weakness and will be tracked by the NRC as Inspector Followup Iter (IF1) (IFl 50-32S/90-06-02). The licensee did not agree to accelerate their effort at this time.
No violations or deviations were identified.
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SolidRadionctiveWeste(83750)
The inspectors reviewed the licensee's sclid radioactive waste management i
prograrn, including: adequacy of implementing procedures to properly
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classify and cheracterize waste, prepare manifests, mark packages, overall perfcnnance of the process control and QA programs, and the adequacy of required records, reports, and notifications.
10 CFR 20.311 requires a licensee who transfers radioactive waste to a land disposal facility' to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.56. It further establishes specific requirements for conducting a quality control program.
The inspectors reviewed the methods used by the licensee to assure that waste was properly classified, met the waste form and characteristic requirements of 10 CFR 61, met the disposal site license conditions, and l
discussed the use of these methods with licensee representatives. During
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the pipe replacement on Unit 2, the licensee performed a chemical
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decontamination of the recirculation system. The inspectors determined that the licensee had collected and stored the filter media used in the i
system cleanup. The licensee had sampled the material and had submitted I
the sample for radioisotopic analysis by a laboratory vendor. The licensee
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was waiting on the results to be used in classifying the radioactive
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waste.
The inspectors determined that the licensee had contracted the services of different vendors for dewatering and solidification of liquid radioactive waste. The new equipment was similar in design to the equipment replaced.
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The licensee had reviewed the vendors Process Control Program and operating procedures for the dewatering system.
The licensee verified that the licensee's program had been reviewed and approved by the NRC in October 1986.
The vendor had modified the dewatering system to include a
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rapid dewatering method to be used at the licensee's facility. The j.
licensee also reviewed a 10 CFR 50.59 evaluation of the vendor changes to
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the dewatering system, and determined that the changes did not constitute a safety hazard.
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No violations or deviations were identified.
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9.
Transportation Of Radioactive Material (83750)
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L 10 CFR 71.5 requires that licensees who transport licensed material outside the confines of its plant or other place of use, or who delivered
lit.ensed material to a carrier for transport, shall comply with the
applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts 170 through
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10 CFR 71.91 specifies the records that the licensee is required to maintain for each nonexempt shipment of radioactive material. The inspectors reviewed selected records of radioective material shipments nede in 1990 and verified that the licensee had maintained the records required by 10 CFR 71.91.
The inspectors verified that the radioactive manifest reviewed by the licensee had been properly completed.
The inspectors reviewed plant procedures for the preparation, documentation, shipment. and receipt of radioactive material and verified that the procedures were consistent with regulations.
The inspectors observed the preparations for a shipment of dry active waste being shipped to a vendor for compaction. The inspectors reviewed the associated paperwork and made independent radiation surveys of the shipment packages and transport vehicle.
No violations or deviations were identified.
10.
Licensee Actions on Previously Identified Inspector Findings (92701 and 92702)
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(Closed)IFI 50-325/88-33-01:
Increased management support is needed for the ALARA program.
The inspectors reviewed licensee data that showed improvement in establishing challenging annual department dose goals.
In addition, management formed an ALARA review connittee comprised of plant managers. This item is closed, b.
(Closed)IFI 50-325/88-33-02: Contractors are not held accountable for dose expended on specific tasks.
While utility chose not into incorporate dose goals as an incentive / penalty in the current outage
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contract with the major vendor, they have discussed this concept with
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other utilities and are training contract administrators in the concept. This item is closed.
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(0 pen) IFI 50-325/88-33-03:
The number of people onsite with measurable dose is consistently higher than the industry norm.
Data for 1989 showed that this is still a problem. This item remains open, d.
(0 pen) IFI 50-325/88-33-05:
The corporate audit program is not resulting in ALARA program improverrents.
The licensee's ccrporate
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group has not perfomed an ALARA audit since this item was last addressed _ in iusnection report tuber 8%33, th0Ntore, the U1 will i
N reviend afur torporate ;srforns thc reyt 6ndit.
The iter will
tumain open.
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e, (Closed)IFI 50-326/88e33-06: A mechanism should be established to require additional ALARA reviews prior to exceeding ALARA job projections. The inspectors were satisfied with licensee progress in i
performing additional ALARA job reviews.
This item is considered closed, f.
(Closeu) IFl 50-325/88-33-07:
Dose resulting from rr. work has not been adequately identified and tracked. The inspectort reviewed date.
taken by the licensee that showed rework was not a problem in the current RPRP outage. This item is closed.
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(0 pen)IFI 50-325/88-33-08: The estimates of man-hours needed to perform a job are f requently overestimated and result in discrepancies between estimates and actual person-hours worked.
Based on interviews with ALARA representatives, this is still a problem with some departments. This item remains open.
11. Exit Interview i
The inspection scope and results were summarized on February 2,1990, with
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those persons indicated in Paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results listed below, lhe licensee identified are-decisional inform 6 tion in the possession of the inspectors and tie document was returned.
Otherwise, the licensee did not identify as proprietary any of the material provided to, or reviewed by the inspectors, during this inspection. There were no dissenting coments regarding any of the inspection findings.
Item Number Description Reference 50-325, 324/90-06-01 VIO - Failure to maintain access to high l
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radiation areas locked (Paragraph 4).
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50-325/90-06-02 IFI - Develop and implement a comprehensive source term and collective dose reduction
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program with actions and target dates for completion (Paragraph 7).
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