IR 05000324/1981016

IE Insp Repts 50-324/81-16 & 50-325/81-16 on 810727-29. Noncompliance Noted:Quarterly Whole Body Dose Limit Exceeded,Inadequate Survey of Radiation Hazards & Failure to Ensure That Technicians Meet ANSI NI8.1-1971 Criteria

ML20054K947
Person / Time
Site:	Brunswick
Issue date:	09/03/1981
From:	Collins T, Hosey C, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20049H201	List: IR 05000324/1981016 ML20049H196 ML20049H296 ML20054K939 ML20054K945
References
50-324-81-16, 50-325-81-16, NUDOCS 8207060327
Download: ML20054K947 (6)

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p sma nou UNITED STATES 8 2,g NUCLEAR REGULATORY COMMISSION

[, . g REGION 11 5 8 101 MARIETT A ST., N.W.. SUITE 3100 e [ ATLANTA, G EORGl A 30303

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Report Nos. 50-324/81-16 and 50-325/81-16 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: Brunswick Docket Hos. 50-324 and 50-325 License Nos. DPR-62 and DPR-71 Inspection at Brunswick bant near Southport, North Carolina Inspectors: I _3 D)aesigne/

G. L. Troup d

$ .. M -,0 T. R. Col i ) 0 to igndd m [/__

ApprovedC.by:_kt M. I se ,_ _kcting section Chief te 'Si gned Technical Inspection Branch Engineering and Technical Inspection Division SUMMARY Inspection on July 27-29, 1981 Areas Inspected This routine, unannounced inspection involved 31 inspector-hours onsite reviewing the circumstances surrounding the exposure of a worker to radiation in excess of the whole body regulatory limit and general observation of hecith physics prac-tices, including posting, labeling and control, instruments and equipment, and housekeepin Results In the areas inspected, three violations were identified (exceeding quarterly whole body dose limit, inadequate survey of radiation hazards; and failure to ensure technicians in responsible positions met ANSI N18.1-1971 c ri te ri a ) .

8207060327 811231 PDR ADOCK 05000324 G PDR

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e REPORT DETAILS Persons Contacted Licensee Employees

• C. R. Dietz, General Manager, Brunswick Plant R. E. Morgan, Plant Operations Manager

• G. J. Oliver, Manager, Environmental and Radiation Control

• R. F. Queener, Project Specialist, Radiation Control

• L. F. Tripp, Radiation Control Supervisor E. H. Norwood, Training Coordinator

• J. L. Kiser, ALARA Specialist R. M. Poulk, Regulatory Specialist

• C. S. Bohanan, Regulatory Specialist R. D. Pasteur, E&C Supervisor Other licensee employees contacted included 2 technicians and 1 mechani Other Organizations CP&L Corporate Office

• B. H. Webster, Manager, Environmental and Radiation Control NRC Resident Inspectors

• D. F. Johnson

• L. W. Garner

• Attended exit interview Exit Interview The inspection scope and findings were summarized on July 29, 1981 with those persons indicated in paragraph 1 above. The general manager acknowl-

! edged the two violations which had been identi fied and the inspectors comments regarding the observations during the plant tour The General-Manager was informed on August 26, 1981' that failure of the radiation

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control technician who permitted the work on the reactor water cleanup system valve to continue without performing an adequate evaluation to meet the experience requirements of ANSI N18.1-1971 would also be considered a violation.

! Licensee Action on Previous Inspection Findings l

Not inspected.

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4. Unresolved Items Unresolved items were not identified during this inspectio . Notification of Overexposure On July 17, 1981, the licensee notified a Region II radiation specialist by telephone that an overexposure had occurred on that date. The individual who was overexposed received a whole body dose for the third calendar quarter of 4212 mrem; the NRC limit is 3000 mrem per quarter. A second individual received a whole body dose for the quarter of 2188 mrem, which is less than the NRC limit but exceeded the licensee's administrative control limit of 1000 mrem per quarte . Description of Event On July 17 work was initiated in Unit 2 under radiation work permit (RWP) 717-12 to attempt to free up the reactor water cleanup system (RWCU) filter "B" resin discharge valve (valve 33-B) so it could be operated. Attempts to manually operate the valve on the morning of the 17th were unsuccessful. On the af ternoon of the 17th two groups of mechanics were sent in to attempt to open the valve. Radiation levels near the valve were 50-300 mR/h The first group (mechanics "A" and "B") , accompanied by radiation control technician "C" entered the valve area and loosened the piping flanges. The valve could be operated after the flanges were loosened and the valve was cycled by one of the mechanics. The mechanics exited the area. Radiation control technician "C" then started to collect a airborne activity sample and took a radiation survey of the work area; a radiation level of 30R/hr was measured on valve 33- Mechanics "D" and "E" were preparing to enter the area to tighten the piping flanges and complete the work, accompanied by radiation control technician "F". Upon exiting the area, technician "C" informed technt-cian "F" of the high radiation levels in the work area. Technician "F" told mechanics "D" and "E" that, based on the 30R/hr radiation level, their allowable stay time would be 2 minutes. The mechanics stated that it would take longer than that just to enter and exit the area. After further discussion, it was agreed that the mechanics would accomplish the work as quickly as possible and would exit the area if they encoun-tered any problem The mechanics entered the area, tightened the flanges, installed the valve operator and exited the area. The valve was opened and closed approximately three times during the wor Mechanics "D" and "E" were in the area for approximately 6 minute Upon exiting the area, Mechanics "D" and "E" read their low range (0-200 mrem) dosimeters and found that the dosimeters were off-scal The high range dosimeters (0-5 Rem) indicated 4.5 Rem for mechanic "D"

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6 and 2.2 Rem for mechanic "E". Subsequent evaluation of the TLD's indicated a total dose for the 3rd quarter for mechanic "D" of 4.21 Rem and 2.19 Rem for mechanic "C". Mechanics "A" and "B" both received doses of 220 mrem, based on dosimeter readings.

! Personnel Exposure

! CFR 20.101 (L' allows the licensee to . permit an individual to

, receive a total o, . iational dose of 3 Rem per calender quarter,

provided that the v ' . vable lifetime dose is not exceeded and a Form NRC-4 has been comples .. An inspector reviewed the exposure history

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for mechanics "D" and "E" and determined that both individuals had

completed Form NRC-4, their allowable lifetime doses had been deter-mined and that the exposure received, when added.to their accumulated doses, did not exceed their allowable lifetime dose ;

l Mechanic "D" received a whole body dose for the quarter of 4.21 Rem, I

which exceeds the allowable dose of 3 Rem. This is a violation of 10 CFR 20.101(b) (324/81-16-01). Internal Exposure

Because of the contamination levels encountered in the area, and the pene-tration of a highly radioactive system, the RWP for the work required air-supplied respirators be worn. After completion of the work, mechanics

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"D" and "E" received whole body counts to check for any internal exposur Neither individual showed any detectable internal radioactivit . Surveys

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l CFR 20.201(b) requires that the licensee make such surveys as may be necessary for him to comply with the regulations .in 10 CFR 20. As i

defined by 10 CFR 20.201 (a), " survey" means an evaluation of the radiation hazards, including measurement of radiation levels,

' The initial radiation surveys performed for the RWP showed radiation levels of 50-300 mr/hr. Following the initial phase of the work (breaking the flanges), radiation levels of 30 R/hr were measure Although the radiation levels had increased by a factor of 100 from those measured prior to the start of work, no action was taken by the

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radiation control technician covering the job to: (a) stop work, (b)

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inform his supervision of the increase in levels, or (c) take addi-

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tional surveys of the work area prior to allowing the mechanics to enter the area. A survey taken in tle area after the overexposure had been identified showed radiation lesels of 40-47 R/hr at contact with the piping and valve 33-B and 30 R.'hr at approximately 18" from the piping.

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4 After technician "C" had informed him of the 30 R/hr radiation level, technician "F" had established a stay time of 2 minutes for the mechanics. When told that the work could not be accomplished in 2 minutes, rather than stopping work and evaluating the situation or informing the supervisor, he permitted them to enter the area to accomplish the work "as quickly as possible." The initial evaluation of stay time was discarded without adequate evaluation of the conse-quences on doses. Also, the stay time, based on the licensee's admin-istrative exposure limit, neglected the previous exposures received by both mechanics during the quarte The above conditions represent inadequate evaluations of working conditions which affected the ability to comply with the exposure limits of 10 CFR 20.101 (b). Consequently, they comprise an inadequate survey as defined by 10 CFR 20.201(b). This is a violation (324/81-16-02). An inspector reviewed the training records for mechanic "0" and techni-cian "F". Mechanic "0" had last attended radiation safety retraining in October 1980. Technician "F" has worked in the radiation control group for approximately 14 months, including training periods. Tech-nical Specification 6.3.1 states, in part, "Each member of the unit staf f shall meet or exceed the minimum qualifications of ANSI N1 for comparable positions. Paragraph 4.5.2 of ANSI N1 states " Technicians in responsible positions shall have a minimum of two years of working experience in their specialty."

The technician lacked the experience to be considered " qualified for a responsible position." His actions with regard to changing radio-logical conditions appeared to be a contributing factor to the over-exposure. The inspector stated that failure of the technician to meet the experience requirements of ANSI N18.1-1971 was a violation of Technical Specifications 6.3.1 (324/81-16-03).

10. Subsequent Actions Following the determination that an overexposure had occurred, the licensee conducted a critique on July 17, 1981. A licensee management representative informed the inspectors that the specific actions taken as a result of the critique will be described in the report to be submitted in accordance with 10 CFR 20.405. The preliminary corrective actions were discussed with an inspecto As mechanic "D" had exceeded the NRC quarterly limit of 3 rem and the licensee's annual administrative limit of 5 rem, and mechanic "E" was approaching the annual administrative limit, both mechanics were transferred to non-radiological work for the remainder of the yea Technician "F" has been removed from work with the survey group and will receive additional training and requalification before he returns to this type of wor _

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11. Posting, Labeling and Control An inspector reviewed the licensee's posting and control of radiation areas, high radiation areas, contamination areas, radioactive materials areas and the labeling of radioactive material during tours of the plant. No viola-tions or deviations were observe . Instruments and Equipment An inspector observed a variety of radiological instruments (portable survey instruments, portal monitors, personnel friskers, pocket dosimeters) in use and available for use, checked calibration stickers, performed battery checks for selected portable instruments in the health physics office for proper operations. The inspectcr had no further question . Facility Tour An inspector observed the licensee's current practices for plant housekeeping and contamination control. The inspector observed no buildup of trash or debris, and personnel were observed properly using friskers upon exits of radiation controlled area A licensee representative stated that they have hired an outside contractor to perform the services of plant housekeeping and decon-tamination, which reports directly to the Radiation Control Sectio The inspector concluded based upon his observations that plant house-keeping and contamination control were being adequately controlle The inspector had no further questions.