IR 05000324/1990025
| ML20058L735 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/26/1990 |
| From: | Potter J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058L733 | List: |
| References | |
| 50-324-90-25, 50-325-90-25, NUDOCS 9008080056 | |
| Download: ML20058L735 (15) | |
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, UNITED STATES
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^ REGION 11 '
NUCLEAR REGULATORY COMMISSION
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,101 MARIETTA STREET. N.W..
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ATLANTA, GEOR01 A 30323
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Report Nos.: 50-325/90-25.and 50-324/90-25
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. Licensee: Carolina: Power and Light Company P. O. Boy.-1551
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Raleigh, NC 27602
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Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62:
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Facility.Name:.B'runswick'I and 2
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Inspection Conducted:
ly 9 - 13, 1990
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-Inspector:'
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F.1, Wright
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' Approved by:
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J. P. P~ otter, Ch W -
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. Facilities Radiation-Protection Section
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Emergency Preparedness and' Radiological-
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-Protectign' Branch
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' Division'of Radiation-Safety and Safeguards-
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SUMMARY-
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l Scope:
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t 1This unannounced : inspection of radiation protection activities included.a.
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tuview of' thel. licensee's organization and management controls and onsite.
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(follow-up of events 'at: the facility. In particular, the inspection: reviewed an.
'eventL which: occurred on July 5,1990, in ~ which an. individual. replacing;a traversing;incore probe (TIP) was inadvertently exposed tol radiation;
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LResults:
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Three-apparent violations were identified: (1)' failure to adequately evaluate o.
?p f Lthe L radiation. hazards present during modification ~ of a TIP; (2) failure to-P establish. adequate' procedures to control z radiation dose to workers during.
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. maintenance'and modification work; andc(3)-failure 4to' provide adequate training to; modification personnel' inh the precautions. and procedures to minimize
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' personnel exposures..
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i REPORT DETAILS
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Persons Contacted Licensee Employees
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- K Alton, Manager, Regulatory Compliance
- A. Cheatham, Manager, Environmental and Radiation Control (E&RC)
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- W. Dorman, Manager, Quality Assurance and Quality Control
- J. Harness, General Manager
- J. Harrell, Manager, Projects
- R. Helme, Manager, Technical Support
- J. Henderson, Ma: ager, Radiation Controls, E&RC
- J. Holder, Manager, Outage Management and Modifications
- M. Jones, Manager, On-Site. Nuclear Safety.
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- W. Link, Senior Specialist, Regulatory Compliance
- J. Moyer, Technical Assistant to Plant General Manager A. Padgett, Manager Health Physics Services
- G. Peeler, Mt. nager, Planning and Scheduling L
- D. Saccone, Project-Engineer
- W. Simpson, Manager, Control and Administration
- R. Smith, Manager, Radiation Controls, E&RC
- S.-Smith, Manager, Unit 1 Instrumentation and Control
- J. Terry, Radiation Control Project Specialist
- J. Titrington, Manager, Operations Support
- R. Warden, Manager, Maintenance G. Worley, Radiation Control Foreman - Radioactive Waste Other. licensee employees contacted during this inspection included j
technicians, engineers, and office personnel.
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Nuclear Regulatory Commission
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- B. Levis, Resident Inspector
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- Attended exit interview held July 13, 1990-2.
Onsite-Followup of Events at Operating Power Plants (93702)
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Synopsis of the TIP Modification Event On. July 5,1990,. three Instrumentation and Control (I&C) technicians-
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entered.a TIP drive mechanism contamination control tent located-in-
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'the Unit 1 Reactor Building to complete a modification of the TIP system. The modification involved the installation of a new TIP
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detectors and cables. During calibration of the "D" TIP, the detector and cable were removed directly out of the core into the technicians work area at the
"D" TIP drive mechanism. The TIP detector had a contact dose rate of approximately 1,000 roentgen per hour (R/hr)
-resulting in a whole body dose in excess of 400 millirem (mrem) and an
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extremity dose in excess of 6.9 rem to one of.the workers. The event
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presented a potential-for. personnel exposures in excess of
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10 CFP, 20 limits. An exposure time of 50 seconds could 6 o
..sul ted A' a in a dose ~ in excess of 10 CFR 2011mits for whole. boa
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contact dose time of 15 seconds could have resulted v s4 inaity dose greater than limits specified in 10 CFR 20, b.
TIP System Description and Modification Objectives (1) TIP System Description TIP System was designed to measure and map the axial neutron
. flux profile at radial positions and.-for use in calibrating
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Local Power Rate Monitors (LPRMs). The system included four TIP
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units, each had a detector, detector drive cable / signal lead, a drive mechanism, reel assembly, shield chamber, shear valve, ball valve, index mechanism, purge system, four way connectors, monitor, and guide tubes. A block diagram of the system is shown in Figure 1. The key components associated with 'i? modificetion event on July 5, 1990, were the drive mechanism or drive box and the TIP detector and cable.
TIP Drive Mechanisms: The purpose of the E P drive mechanism was to move the TIP in and out of a set of instrument guide tubes.
Each drive, mechanism consisted basically of an air tight enclosure or " box" housing an electric motor, take-up rcel to-store detector ~ cable, and a travel indicator to indicate -
detector location. The TIP drive-mechanisms on Unit I were located in the north west -section of the Reactor Building on the 20 foot elevation near the personnel access hatch.
TIP Shields Chambers: The shields were located in the TIP Room for storage when not in use. The TIP Room was locked ano
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controlled as a high radiation area.
TIP Detectors: The. originally installed TIPS utilized a neutron probe or detector to measure the neutron flux. The detectors
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were fission chambers similar to the LPRMs. The gamma detectors
are sealed ion chamber detectors designed to measure core ganna flux.
(2) -TIP System Modification The neutron detectors were being replaced with gamma detectors to improve thermal limit monitoring. The licensee needed the-extra thermal margin for the licensee's new fuel design (GE10),
which was scheduled for Unit 1 Cycle 8. The new fuel would intentionally introduce unequal water gaps. The licensee was installing the ganna detectors during Cycle 7 to allow comparison of neutron verses gamma de+ector performance and gain
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experience with them before they were needed in Fuel Cycle 8.
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The gamma detectors had an advantage over the neutron detectors,
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in that, the ganrra probes or detectors reduced TIP asymetry problems caused by unequal water gaps created by bent TIP instrument tubes 'and channel bow. The gama detectors were preferred when such conditions existed because they measured the
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game flux that was not as sensitive to the amount of wate-(moderator) around the instrument tube. The use of the gama TIPS would reduce the probability that the Unit would have to be de-rated due to thermal limits.
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TIP modification number 87-241, was approved in October 1988 by
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the Plant General Manager. ~ ae nodification was originated by engineering work request 84-797 which authorized the Technica.
Support Discipline Engineering to develop a modification package to replace the TIPS. The modification was to perform hardware changes associated with a gamma TIP retrofit on Unit 1. The changes included: replacing the neutron TIP with gama TIPS, replacing the TIP detector cable, and replacing the flux probe monitor. The inspector reviewed the licensee's design package
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that included the following sections; functional Summary, Design Bases. Installation Procedure, Acceptance Test, Document Revision, and Required Staff Review.
The 14.ensee made the decision to implement the modification
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shot t.'.y before June 25, 1990. The licensee was nearing the end of the fuel cycle and hoped that the new detec. ors would allow better core flux profile and potentially allow additional rod
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movenents to increase the efficiency of the core.
In interviews with the TIP Modification Project Engineer. the inspector determined that numerous planning meetings
(approximately 12) had been conducted since November 1989. 1ic i
project involved numerous work groups. TAs prinary groups
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involved with replacing the TIPS included Outage %nageiner.
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Modification (OM/M), Maintenance Unit ! I&C/ Electrical, at J ALARA/E&RC. Through interviews with project engineer the inspector determined that the licensee held a project briefing
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with all groups prior to project irnplensentation. Licenc e
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i representatives also reported that informal pre-job briefine;s l
were held with Health Physics (HP) and Mt technicians prior to i
each major evolution.
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Scenario of the TIP Modification Event The licensee planned to remove all detectors on Monday July 2,1990, and completed thas portion of the job by 1:00 p.m. During removal of
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the old TIPS, the licensee maintained constant HP coverage until the detectors were removed to the spent fuel potl and the cables were transferred to radioactive waste facilities.
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On July 3,1990, the licensee installed the new TIP drive / signal cables on take-up reels and installed the "A" TIP.
On July 5,1990, the licensee planned to complete the modification. A pre-job briefing took place in the morning and the licensee completed installation for
"B" detector. After a lunch break the technicians held another briefing at 12:30 p.m. before returning to the work area to install new TIPS on the
"C" and "D" TIP drive mechanisms. Two plant and one vendor I&C technicians entered the containment tent to finish the plant modification at approximately 1:00 p.m. The technicians were able to replace the "C" TIPS with out any problems.
After installing the new TIP onto the
"D" drive mechanism the technicians moved the new detector into the longest guide tube to calibrate detector position. While the technicians were doing this they determined that the clutch for the take-up reel was making it difficult to insert the TIP. At that time one of the plant 1&C technicians left the containment tent to see about obtaining parts for repairing the problem clutch.
The licensee was able to insert the "D" 'IP to the top of the longest tube and the detector remained there f.,. 3-5 minutes while the probe position was calibrated. Communication between the Control Poom and the TIP drive work area was made with communicstion head sets. The inspector determined that the vendor 1&C techniiian was serving as a connunicator at that time. The technician was c unmunicating with a fourth I&C technician in the Control Room who was monitoring detector position calibration data.
When the proper position had been set, the technicians at the drive mechanism were given permission to withdraw the TIP and to proceed to another guide tube. This sequence required the technicians at the drive box to mar.ually withdraw the TIP from the core to the indexer where another path into the core could be selected and the procedure repeated. The vendor I&C technician from the OM/M group began withdrawing the detector with the manual crank.
The technicians reported that manual TIP movement at the drive mechanism required two workers, one to crank the detector and another to monitor TIP location. The drive mechanism had a TIP position indicator that was difficult to read because of its location in the drive mechanism housing. The technicians had to use an inspection mirror to see the position indicator and monitor the TIP location.
-ff When the OM/M vendor I&C technician began cranking the TIP out of the reactor core, the plant I&C technician's attention was distracted from the TIP position indicator to the troubled clutch, and he was not monitoring the TIP travel position. The inspector determined through interviews with the OM/M vendor I&C technician that he had not received any specific training on TIP system operations and at the time the evert occurred he believed that the TIP would l
automatically stop at the shield. The technician continued to crank
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the TIP out of the core until it entered the drive mechanism housing making a loud sound as it entered the drive box.
When the technician saw the detector, he instinctively reacted to move the detector out of his work area. The technician grabbed the TIP cable with his lef t hand and inserted it into the TIP guide tube.
Once the detector was in the guide tube the detector was cranked back through the guide tube to a location near the indexer. This movement reduced the whole body dose rate in the area to background levels.
The technician in the control room that was monitoring TIP position there had a headset to communicate with the vendor I&C technician at the drive box. The control rocm technici'n noted that the TIP was being moved at a high speed near the indexer and he tried warn the technician moving the TIP at the drive box that continued withdrawal would cause the TIP to enter their work area. However, he was unable to get the vendor I&C technician to stop TIP withdrawal. The vendor I&C Technician reported that he did ' Tot hear a warning from the technician in the control room and that communications had been difficult. The workers were wearing full face respirators and the backcround noise was high from the high effeciency particulate air (HEd) filter serving the drive mechanism t.ontainment enclosure.
The technician that handled the TIP cable was wearing a set of cotton and two sets of rubber gloves. The technician reported that the TIP cable was hot, due to the heat transferred to it while it was in the core, and that as soon as he got the detector out of the drive box area he had to remove his rubber gloves because they were hot. The technician who had left the tent to obtain a clutch part re-entered the tent to crank the detector into the TIP shield in order that the ball valve could be closed. The ball valve was installed between the shield and the indexer and provided a means of sealing the guide tube should a leak develop in the tube. That allowed the licensee to postpone any further work until the event had been assessed by licensee management. The I&C technicians departed the work area at that time, approximately 2:50 p.m.
When the TIP detector passed through the TIP Room and into the drive box, the Area Radiation Monitors (ARMS) in both areas alarmed. This alerted a HP technician in the area who was performing routine radiological surveys. The Radiation Protection Manager (RPM) was in the Reactor Building when the event occurred and was at the TIP drive area within five niinutes, d.
Recovery Operations That afternoon the licensee began recovery from the event. With the detector located in the shield chamber and the ball valve closed the TIP system did not require immediate attention, and the licensee focused on determining personnel doses and necessary steps to allow the work to continue the following day. The licensee canceled all TIP work until an initial assessment could be made and exposure dose i
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rates determined. Licensee management held a meeting that afternoon to determine what had caused the TIP to be accidentally withdrawn.
The licensee had whole body dose measurements from alarming, self-reading, and thermoluminescent dosimeters (TLDs), but did not i:
have any contact radiation dose rate information on the TIP cable and detector or extremity monitoring results. The licensee determined J
contact exposure estimata from measurements made that afternoon and decided to complete the modification work on July 6, 1990.
The licensee notified the h'RC Resident Inspectors of the event
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Friday, July 6, 1990. The licensee revised the radiation work permit
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to require continuous HP coverage and held a pre-job briefing with all Sersonnel having TIP modification responsibilities before work cont <nued. The licensee was eble to complete the modification without further complications.
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Personnel Dose
The I&C technicians had been wearing alarming personnel dosimetry set to alarm at 100 millirem. The vendor 18C technician noticed that his
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alarming dosimeter was giving an alarm signal when he left the TIP containment tent. The technicians TLDs were analyzed and whole body doses were 377 millirem for the vendor IEC technician, 239 millirem for the plant I&C technician, and 50 millirem for the I&C technician that had left the drive box area, t
Information provided in the TIP modification technical description stated that the detectors becar.e activated by in-core radiation exposure were manganese (Mn) primary gamma contributors to their during use and that the two 56 and cobalt (Co) 60, which were materials from which the the TIPS were constructed. The documentation also reported that Mn-56 was the primary contributor to gamma radiation for the first one to two days after irradiation and Co-60 was the primary contributor after that time for TIPS having long i
service times. The gama detector had a diameter of 0.213 inches and a length of 2.595 inches the cable was 0.256 inches in dianeter and a length of approximately 150 feet.
The licensee attempted to determine the dose rate from the TIP detector and cable shortly after the event occurred. Dased upon the design criteria specified in the plant modification package, the licensee made the assumption that the major dose contributor was Mn-54 since the detectors core exposure time was relatively short (3-5 minutes) and the exposure occurred immediately after detector withdrawal. The licensee made the Geiger-Muller (GM) radiation exposure measurenents of the TIPS approximately two hours after initial exposure. Two HP technicians entered the TIP shield room and the TIP was withdrawn so that the radiation measurements could be l
made. Contact measurements of the detector and cable were made with a L
telescoping GM detector. The highest contact reading on the detector or the cable was 500 rem /hr measured on the cable. The licensee also
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i attempted to duplicate a contact hand dose measurement by affixing a TLD to the end of a telescoping detector and holding the TLD in
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contact with the cable for three seconds. The vendor I&C technician
' had originally reported to the HP staff that his estimated hand contact time with with the TIP cable had been three seconds.
The licensee determined the contact radiation exposure of the TIP cable by modifying the measured radiation exposure rate with a decay correction factor for Mn-56 and estimated that the exposure rate was t
906 R/hr. The licensee then calculated a 1.26 R exposure for a five
second exposure period. The licensee then added the technician's 0.377 R exposure inforn.ation inom the whole body TLD and assigned an extremity dose of 1,637 rem.
The licensee experienced difficulty in determining how the contact
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extremity exposure occurred. During ihe licensee's initial assessment
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of the vendor I&C technician's extremity exposure on July 5,1990, the licensee initially determined that the technician had grabbed the detector cable approximately one foot behind the detector with the left hand. The technician also estimated that his hand was in contact with the cable for three seconds on July 5,1990. On July 9,1990, the licensee reported to the inspector that the technician in reviewing the circumstances of the extremity caposure had reported
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that he -grabbed the detector cable approximately seven inches from the detector and that the exposure time may have been up to five seconds. Later in the inspection the inspector interview the vendor I&C technician and the technician reported that in his own review of the event he must have grabbed the cable with his left hand and the detector with his right. That was believed to have been the exposure scenario at the NRC exit meeting on July 13, 1990. However, in a-
telephone conference between G. Cheatham of CP&L and F. Wright of the NRC on July 20, and July 25, 1990, the licensee reported that the I&C technician had not grabbed the detector with either hand and that he
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had kept his right hand on the crank lever and grabbed the detector cable approximately seven inches behind the detector with his Uft hand. The licensee also reported that in reviews of the ind.viduals
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extremity dese, the licensee learned that there was an additional dose contribution from aluminum 28 that had not been included in initial calculations of the employees extremity dose.
The licensee reported that they had determined with the assistance of thc TIP vendor the activation radioactivity of the cable and detector from core exposure time and neutron flux.
The licensee then calculated the contact personnel exposure to be 6.971 rem, of which 3.711 rem
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was due to beta particles.
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Licensee Assessment of the TIP Event
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Licensee management had not made its final assessment of the event by the end of the inspection on July 13, 1990. However, licensee management did believe that the cause of the event was a lack of work control by licensee management. The Plant Manager discussed the i
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position during the exit interview and requested that the inspector
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report that assessment to NRC management. The licenste also requested
an opportunity to discuss that position prior to inspection report issuance. The licensee believed that a violation against poor work
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controls would better define the problem associated with the TIP
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event than the three violations discussed in the following para. graph.
i The inspector determined that there did appear to be a breakdown in work control during the modification. The inspector determined that
although there were three project engineers assigned to the project,
there was not a management representative present at the TIP drive l
work site when the event occurred. Additionally, when the inspector questioned the I&C technicians about task responsibilities, none could state which I&C technician had responsibility for ensuring the tect Ticians were performing duties as required by licensee
)rocedures. The assignment of a technician to the task that did not lave experience with TIP system was also an indication of lack of management controls. The inadequate assessment of the potential
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radiological hazards associated with the job was also an example of inadequate management review of the work activities, g.
NRC Assessment of the TIP Event (1) 10 CFR 20,201(b) requires each licensee 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 i
circumstances to evaluate the extent of radioactive hazards that
may be present.
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10 CFR 20.201(a) defines a " survey" as an evaluation of the radiation hazards incident to the production, use, release, disposal or presence of radioactive materials or other sources of radiation under a specific set of of conditions.
The licensee planned the removal of the old TIPS and provided continuous HP coverage for that portion of the job. The licensee's ALARA staff estimated collective personnel doses for the removal phase of the job would result in 0.1 person-rem. The licensee was able to reduce personnel doses,sr that phase of
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the TIP modification with remote handling tools, shields, end job planning. The actual dose received was approximately one half of the dose estimate (0.05 person-rem).
However, the licensee's staff did not anticipate a TIP withdrawal beyond the TIP shield and believed that the radiological hazards for the planned work did not warrant continuors HP coverage. The inspector determined that the
licenset, typically replaced a TIP every year, and the routine task usually required that a detector be removed and replace in
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This required continuous HP coverage. In the modification the licensee concentrated heavily on the removal of the old detectors and failed to anticipate radiological hazards
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t associated with installation of new detectors. The failure to adequately evaluate the radiation hazards incident to installation and calibration of a TIP was identified as an
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apparent violation of 10 CFR 20. 201(b) (50-325, 324/90-25-01).
(2) Technical Specification (TS) 6.8.1 requires that written
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procedures be established, implemented, and maintained covering 9-the activities recommended in Appendix A of Regulatory Guide 1.33, November 1972.
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Regulatory Guide 1.33, November 1972, Appendix A, Paragraph 9.e states general procedures for the control of maintenance repair, replacement, and modificetion work should be prepared prior to beginning work. These procedures should include information on areas such as the following:
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(a) Method for obtaining permission and clearance for operational personnel to work and for logging such work.
(b) Factors to be taken into account, including the necessity for minimizing radiation exposure to workmen, in preparing
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the detailed work procedures.
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TS 6.11 requires that written procedures for personnel radiation i
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protection shall be prepared consistent with the requirements of i
10 CFR Part 20 and shall be approvede maintained, and adhered to for all operations involving personnel radiation exposure.
TN: 'nspector reviewed the TIP modification procedure in Plant Mcdiiication 87-241 and the plant's TIP replacement procedure M1-16-42, Replacing TIP Detector, Revision'1, dated December 12, 1990, and determined they did not have specific instrections, methods, or precautions to assure activated TIPS are not withdrawn into occupied work areas when the drive units.are in
the manual mode of operation. The failure to establish adequate maintenance and modification procedures with the necessary
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controls to prevent radiation exposures having potential for personnel exposures in excess of 10 CFR 20 was identified as an apparent violation licensee TSs 6.8.1.
and 6.11 (50-325, 324/90-25-02).
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10 CFR 19.12 requires that all individuals working in a restricted area be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such proportions of the restricted area, and be instructed in the health protection problems associated with exposure to such radioactive i
materials or rad.ation, and in the precautions or procedures to
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minimize exposure.
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The inspector rcviewed the lesson plans and training records for the plant I&C personnel working on the TIP modification on July 5,1990. The licensee provided the plant I&C technicians with classroom instruction on the TIP systems and also required maintained qualification cards for staff personnel working with the TIP systems. The inspector reviewed the content of the licensee's training program for the plant I&C technicians and verified that the technicians had received the TIP system training and had completed qualifications records. However, the licensee had not provided TIP system training for the vendor 18C technician that melua11y cranked the detector past the shield chamber into the drive box. In intervie'1s with the vendor I&C technician, the inspector determined that the the technician had not received sufficient training on the TIP system, in that, the worker did not know that the radioactive cable and detector could be manually withdrawn into the TIP drive mechanism housing. The vendor I&C technician reported to the inspector that he thought that the detector would automatically stop when the detector reached the TIP shield chamber. The failure to provide a vendor I&C technician necessary training on the operation and maintenance of the TIP system and precautions or procedures to minimize personnel exposures during operation and maintenance of the TIP system was identified as a violation of the requirements specified in 10 CFR 19.12 (50-324, 325/90-25-03).
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Prior Notice of Similar Events The inspector determined that the licensee had receive IE Information Notice (IN) No. 88-63, dated August 15, 1988. The Notice was provided to licensee's to alert them to an event at another commercial power reactor resulting from licensee failure to adequately evaluate the hazards present during work involving irradiated incore neutron detectors and similar events at other facilities.
The inspector determined that the 88-63 Notice had been reviewed for applicably by the licensee's corporate HP staff. A memorandum from the Corporate Health Physicist to CP&L RPMs, dated November 22, 1988, reported that the the ALARA program at Brunswick, with tight controls of high radiation areas, which included the TIP room, would prevent a similar event at Brunswick. The memorandum also stated that the 88-63 Notice would be reviewed and included in the continuing training sessions for HP technicians and that the Notice would be passed on to Instrumentation Foremen for their staff's review. The inspector determined, through interviews with the RPM, that the licensee had not included the information from the 88-63 Notice in the HP continuing training program or provided the Notice to Instrumentation Foremen in order that they could pass the information on to their personnel. The events at the facility discussed in the Notice and
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those occurring at' Brunswick were simibr lei nveral areas including the following:
The -licensee's failed to adequately evalutte the radiation
hazards present during work on incore detectors.-
Procedures were inadequate in that thi. pro',edures did not contain steps necessary to prevent withdrawal of the radioactive detector and cable into unshielded and occupied areas creating significant potential for personnel exposures in excess of limits specified in 10 CFR 20.
- Cone:unication problems among workers performing TIP work were inadequate.
Although specific actions by it'ensees are not required by ins, licensees are expected to review them for applicability. The licensee
did not appear to have taken advantage of the information contained
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in the 88-63 Notice to help prevent a similar event at the Brunswick facility.
Three apparent violations and no deviations were identified.
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Organization and Management Controls a.
Organization The inspector reviewed changes made to the licensee's organization,-
staffing levels, and lines of authority as they related to radiation i
protection, and verified that the changes had not adversely affected the licensee's thi11ty to control. radiation exposures or radioactivity.
The inspector determined that the former Radiation Control Manager of l
Operations had taken a position with the corporate HP staff. The new Manager of Operations came from within the plant radiation protection staff and, as a result, several staff personnel had changed responsibilities and duties.
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Management Controls i
10 CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to i
maintain radiation exposures a low as reasonably achievable. The
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reconnended elements of an ALARA program are contained in Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be ALAPA, and Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures ALARA.
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The inspector discussed the audit and surveillance program related to radiation protection. The inspector reviewed licensee audit report QAA/0021-90-02A, Quality Assurance Audit of Brunswick Nuclear Project
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ALARA Program conducted April 2 to June 5,1990. The audit staff included technical specialists from CP&L facilities having experience in radiation protection and ALARA activities. The audit identified significant findings concerning the licensee's ability to effectively plan and implenent maintenance and n.cdification activities. The audit cover letter identified the following concerns:
Implementation of the planning and budgeting processes not
adequately supporting the modification design schedules.
Modification field revisions that expand the score or result in
more man-hours in the radiation control area.
Numerous craft personnel that are unfamiliar with the plant
layout; some have little experience in the task that they are performing.
Indicators that son.e of the actions taken to resolve known
problems are already running into difficulties. Their implementation will probably slip unless they are closely monitored and action taken where appropriate.
The inspector noted that the third item above was a contributor to the TIP event of July 5, 1990, that is discussed in detail in this report. The inspector reported to the licensee's management that the Brunswick ALARA audit was a program strength with meaningful and significant findings deserving management attention.
No violations or deviations were identified.
4. Exit Interview The inspection scope and findings were summarized on July 13, 1990, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspections findings listed below. The licensee did not identify as proprietary any of the material prsvided to or reviewed by the inspector during this inspection.
The licensee's Plant Manager took exception to the inspection findings, stating the real problem associated with the TIP modification event of-July 5,1990, was failure of the licensee to control work. The Plant Manager referenced the NRC Maintenance Team inspection criteria for Work Control and stated that the inspector's findings were citations against individual elements of a good work control program. Additionally, the licensee believed the one violation for inadequate work controls appeared to be a more appropriate assessment of the problems.
The Plant Manager
.
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requested the opportunity to discuss the licensee's position with Region 11 NPC management before the inspectors report was issued. The inspector stated that he would notify Region II managenent of the licensee's request.
ItemNungg Description and Reference 50-325,324/90-25-01 Violation - Failure to adequately evaluate the radiological hazards present for TIP niodification work (Paragraph 2).
50-325,324/90-25-02 Violation - Failure to establish adequate procedures for TIP replacement (Paragraph 2).
50-325, 324/90-25-03 Violation - Failure to provide a vendor technician with instructions, adequate precautions, or procedures to minimize exposure when operating TIP drive equipment (Paragraph 2).
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