IR 05000324/1997014

Insp Repts 50-324/97-14 & 50-325/97-14 on 971209-12. Violations Noted.Major Areas Inspected:Radiation Protection & Chemistry Controls,Miscellaneous Radiation Protection & Chemistry Issues & Mgt Meetings

ML20198N656
Person / Time
Site:	Brunswick
Issue date:	12/30/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198N643	List: IR 05000324/1997014 ML20198N639 ML20198N646 ML20198N656
References
50-324-97-14, 50-325-97-14, NUDOCS 9801210160
Preceding documents:	ML20217Q515 (2 March 1998)
Download: ML20198N656 (7)

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4 l1 S. NUCLEAR REGULATORY COMMISSION REGION 11 ,,

Docket Nos: 50-325, 50-324 License Nos: DPR-71. DPR-62 Report No: 50-325/97-14, 50 324/97-14 Licensee: Carolina Power & Light (CP&L)

Facility: Brunswick Steam Electric Plant. Units 1 & 2 Location: 8470 River Road SE Southport. NC 28461 Dates: December 9-12, 1997 Inspector: W. Rankin. Senior Project Manager Approved by: K. Barr, Chief. Plant Support Branch Division of Reactor Safety

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9901210160 971230 PDR ADOCK 05000324 G PDR Enclosure 2

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EXECUTIVE SUMMARY Brunswick Steam Electric Plant Units 1 & 2 NRC Inspection Report Nos. 50J> /97-14 '50-324/97-14 Plant Sunoort e The radiation control program uas effectively implemented with good occupational exposure controls c5 served during norndl plant operations, (Section R1.1)

e The licensee's_off-site dose projection software. CPLDOSE, was evaluated and determined to be functioning as designed with no flaws identifie (Section R8.1)

e Ona violation was identified for failure to control a Locked High Radiation Area in accordance with procedure. (Section RI.1)

'e One violation was identified for failure to initiate a condition report

- upon identifying a Locked High Radiation Area not co.ntrolled in accordance with procedure. (Section R1.1)

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Report Details Plant Support R1 Radiation Protection and Chemistry Controls R1.2 Extern; Occooational Exoosure Conttch Insoection Scooe (83750)

The inspector evaluated aspects of the licensee's radiation control program against the applicable requirements of 10 CFR Part 20. Technical Specifications, and the Updated Final Safety Analysis Report (UFSAR).

The inspector also evaluated licensee radiological controls with emphasis on on external occupational exposure during normal plant operation Observations and Findinas The inspector made tours of the radiation control area, observed compliance of licensee personnel with radiation protection procedures for routine work evolutions, and conducted interviews with licensee personnel with respect to knowledge of radiation controls and specific radiological working condition During plant walkdowns within the Radiologically Controlled Area IPCA),

the inspector conducted brief interviews at random with radiattor, workers inside the RCA in order to determine the level of understanding of Radiation Work Permit (RWP) requirements and radiation working conditions. The workers interviewed were verified to have signed on to an RWP. were wearing dosimetry appropriate to their work activities

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within the RCA, and were performing specific work activities on appropriate RWP The inspector reviewed total effective doses for radiation workers at s

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the site and determined that all personnel exposures assigned since the beginning of 1997 through December 11, 1997 were within 10 CFR Part 20 limits. The inspector determined that the licensee had adequately monitored and tracked individual occupation ' radiation exposures in

\ accordance with 10 CFR Part 20 requirements and that doses reported were at a small percentage of regulatory limit The inspector reviewed and discussed with licensee representatives the program for satrolling access to high radiation areas (HRAs), locked .

high radiation areas (LHRAs). and very high radiation areas (VHRAs).

These areas were inspected during tours of Unit 1 and Unit 2 for proper posting and access controls. No HRAs. LHRAs. or VHRAs were identified where required posting was needed but not posted. Areas controlled as-a LHRAs-were inspected and found locked in accordance with licensee

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procedure. Key controls for entry into locked and very high radiation areas were evaluated against the requirements of the licensee's-administrative control procedure and determined to be controlled in accordance with procedur During evaluation of LHRA controls the inspector reviewed the licensee's use of a 200 Curie Cs-137 source used primarily in the calibration of pocket dosimeters maintained for emergency preparedness purposes. Upon review of radiological surveys conducted during recent uses of the Cs-137 source, it was determined that on November 18. 1997, the area met Technical Specification 6.12.2 LHRA criteria and OE&RC-0040 " Control of Locked High Radiation and Very High Radiation Areas". Rev. 15. Step procedural requirements for an area that must be controlled as a LHRA in that area dose rates exceeded 1 Rem /hr. The applicable survey for the calibration room (Survey No. 1118-30 dated 11/18/97) performed during the calibration work with the Cs-137 source exposed (at the three foot elevation with shields out) indicated 10 Rem /Hr. near the ceiling and 1.5-2.0 Rem /Hr. behind the shield window which constituted general area readings in the room of greater than 1 Rem /Hr. These general area radiation levels in the room at the time met LHRA criteriu and necessitated LHRA controls for the period during which these conditions existed. However. during interviews with radiation control personnel directly involved with the specific controls that were in place at the start of the dosimeter calibration work on November 18. 1997, the inspector determined that the calibration room was not controlled in accordance with LHRA procedural requirements. Specifically, access was not properly controlled and the entrance to the room was not secured with designated special cal-core locks required for LHRAs prior to to leaving the area unguarded. Although the actual doses received by the radiction workers involved with the dosimetry calibration work conducted on November 18. 1997 were small. the radiological controls in place were not sufficient to provide reasonable assurance against the potential for greater exposure. Of particular concern were the insufficient controls for the foot pedal and the " source up" control panel which were not locked out or controlled in any positive manner. Although the door to the calibration room containing the source was maintained locked, insufficient positive control over the door key inventory was eviden The licensee was informed the failure to control tne calibration room as a LHRA was a violation of licensee procedure OE&RC-0040 requirement This is designated Violation 50-325(324)/97-14-01. Failure to control a Locked High Radiation Area in accordance with procedural requirement During discussions with licensee radiation control personnel associated with the November 18. 1997 dosimetry calibration work. the inspector inquired as to the status of corrective actions for the adverse conditions identified. Licensee representatives indicated that immediate corrective actions were undertaken at the time of the incident to include dedicated job coverage by a qualified Radiation Control I

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Technician through completion of the dosimeter calibration work. The inspector determined, however, that no follow up_ corrective actions had occurred and in fact, the incident was ncver documented in Condition Reports despite the relative significance of a failure to control a LHRA in accordance with TS and procedural requirements. 10 CFR 50. Appendix B. Criterion XVI, requires that measures shall be established to assure that conditions adverse to quality, such as deficiencies and nonconformances, are promptly identified and corrected. CP&L Procedure PLP-04. " Corrective Act'on Management". Revision 23. dated 10/27/9 mplements the requirements of Criterion 16 at the Brunswick Nuclear Plant. Attachment 6 of PLP-04. " Criteria for Condition Reports", states under examples of conditions which should be Condition Reports, a person who does not mmply with procedure requirements such as passes material across a contamination barrier or who does not frisk when require Paragraph 6.0 of PLP-04 requires that personnel shall review their activities for adverse conditions which meet the threshold for initiating a Condition Report and, upon identifying such a condition, personnel must initiate a Condition Report. Contrary to this procedural requirement. on November 18. 1997, the licensee failed to initiate a Condition Report upon identifying a LHRA not properly controlled in accordance with procedures, an adverse condition which met the threshold for initiating a Condition Report. The licensee was informed this failure to initiate a Condition Report in accordance with procedure was a violation and is designated Violation 50-325(324)/97-14-02. Failure to initiate a Condition Report for a LHRA not properly controlle Conclusions The radiological controls program was effectively implemented with good occupational exposure controls demonstrated overall during routine plant operations. However, one violation was identified for failure to control a Locked High Radiation Area in accordance with procedural requirements. Another violation was identified for failure to initiate a Condition Report for the LHRA not properly controlle R8 Miscellaneous Radiation Protection & Chemistry Issues R8.1 Offsite Dose Projection Under Acci P t Conditions Insoection Scoce (827011 The inspector evaluated the licensee's capabilities to provide off-site radiological dose projections during accident conditions consistent with the requirements of the licensee's emergency plan and plant emergency procedure OPEP-03.4.7. "Offsite Dose Projection". Rev.10. Emphasis was given to capabilities of the licensee's dose projection softwar CPLDOSE. to provide dose projections for spent fuel handling accidents.

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I 4 Observati.gn s and Findinas The inspector evaluated the dose projection capabilities of CPLDOSE under accident conditions involving a dropped fuel bundle and related fuel handling accident scenarios. Specifically examined was the design basis refueling accident in which one fuel assembly is assumed to fall on to the top of an uncovered reactor core as analyzed in Section 15. of the UFSAR. A review of CPLDOSE and projected outputs verified that the CPLDOSE dose projection methodoloay made valid dose projections for this bounding " worst case" fuel handling accident condition under a range of source terms, durations, and atmospheric dispersion factor The inspector also reviewed a condition report (CR-02632 dated 7/31/97)

which stated that the CPLDOSE source term was potentially invalid for fuel handling accidents because reactor shutdown time was believed to affect source term calculations for fuel handling accidents. The CR stated that data input for the variable time since reautor shutdown should have little correlation to a fuel handling accident dose projection. The inspector reviewed with the licensee's senior HP analyst with technical cognizance for the CPLDOSE methodology the licensee's evaluation for closure of the condition report. This evaluation contained analysis for old spent fuel (>5 yrs.) and current spent fuel and projected the off-site dose consequence for a series of reactor shutdown times. In each case the source term changed with time as expected and the dose projection model was validated for the input data. The inspector reviawed the evaluation and determined the analysis to be valid with reasonable assumptions used. No errors were identified in the dose projection methodology during this review. During the period of time that CPLDOSE was under a five evaluation for the potential error above (7/31/97 until 8/13/97), the inspector was able to verify with operations personnel that no fuel movements had occurre c. Conclusions The licensee's offsite dose projection software. CPLDOSE was evaluated and determined to be functioning as designed with no flaws identifie V. Manaaement Meetinas X Exit Meetina Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on December 12, 1997. The licensee acknowledged the findings presente .

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PARTIAL LIST OF PERSONS CONTACTED L1sAufER M. Christinziano. Manager. Environmental and Radiation Control R. Crate. Superintendent. Radiation Protection S. Hinnant. Vice. President. Brunswick Steam Electric Plant W. Hinson, Radiation _ Control Supervisor-Dosimetry K. Jury. Manager, Regulatory Affairs J. Lyash. Plant General Manager D. Pacini. Radiation Control Supervisor T. Priest. Radiation Control Supervisor P. Sawyer. Radiation Control Supervisor S. Tabor. Senior Specialist. Regulatory Compliance Other licensee employees or contractors included office, operations, chemistry, and radiation control personne IEC E. Brown Resident Inspector E. Guthrie. Resident Inspector-C. Patterson. Senior Resident Inspector INSPECTION PROCEDURES USED

IP 83750: Occupational Radiation Exposure Controls ITEMS OPENED. CLOSED, AND DISCUSSED Onened-50-325(324)/97-14-01 VIO Failure to control a Locked High Radiation Area in accordance with procedure (Section R1.1)

50-325(324)/97-14-02 VIO Failure to initiate a condition report upon identifying a Locked High Radiation Area not controlled in accordance with procedure (Section Rl.1)

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