ML20056D166
| ML20056D166 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/02/1993 |
| From: | Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20056D160 | List: |
| References | |
| 50-324-93-28, 50-325-93-28, NUDOCS 9308050051 | |
| Download: ML20056D166 (6) | |
See also: IR 05000324/1993028
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UNITED STATES
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NUCLEAR REGULATORY COMMisslON
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EEGION 11
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101 MARIETTA STREET, N.W.
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ATLANTA. GEORGI A 30323
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JUL 02 ng3
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Geport Nos.: 50-325/93-28 and 50-324/93-28
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
Facility Name:
Brunswick 1 and 2
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Inspection Conducted: June 1-4, 199
Inspector:
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R. B. Shortridge
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Date' Signed
Approved
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W. H. Rankin, Chief ~
Dit6 Signed
Facilities Radiation Protection Branch Section
Radiological Protection and Emergency Preparedness Branch
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Division of Radiation Safety and Safeguards
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SUMMARY
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Scope:
This was a special, announced inspection to review the circumstances
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surrounding the method of issuing of digital alarming dosimeters (DADS) to
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individuals entering high radiation areas and the understanding by operations
personnel on the use of DADS.
In addition, the inspector reviewed a Licensee
Event Report (LER) which reported a problem with, and corrective action for,
detecting Fe-55 subsequent to a sealed source leak test.
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Results:
In the areas inspected, two violations were identified and a number of
associated concerns were addressed. The inspector identified that the
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unauthorized issuance of a DAD by an auxiliary operator was a violation of .
licensee procedures. The second violation was the failure of the licensee to
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adequately' train operai. ions personnel- in the use of DADS.
The issue
discussed in the LER was identified and corrected by the licensee and was
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determined to be a non-cited violation (NCV).
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930B050051 930702
ADOCK 05000324
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REPORT DETAILS
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Persons Contacted
- K. Ahern, Manager, Operations Support and Work Control
- G. Barnes, Manager, Unit 2 Operations
- S. Callis, On-Site Licensing Representative
- J. Fergueson, ALARA Specialist, Radiation Protection
- C
Hinnant, Director Site Operations
- T. Jones, Senior Specialist, Regulatory Compliance
- W. Levis, Manager, Regulatory Compliance
- G. Miller, Manager, Technical Support
- E. Northein, Manager, Nuclear Engineering Department
- C. Scacher, Project Engineer, Nuclear Assessment Department
- R. Schlichter, Project Engineer, Nuclear Assurance Department
- R. Smith, Manager, Radiological Controls
- P. Snead, Manager, Radiological Controls
- S. Tabor, Senior Specialist, Investigations
- J. Terry, Senior Specialist, Radiation Protection
- J. Titrington, Manager, Unit 1 Operations
- H. Wall, Manager, Shift Operations Unit 2
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- C. Warren, Plant Manager, Unit 2
- G. Warriner, Manager, Control and Administration
- S. Watson, Manager, Environmental and Chemistry
Other licensee employees contacted during this inspection included
operators, technicians, and administrative personnel.
Nuclear Regulatory Commission
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- P. Byron, Resident Inspector
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- C. Christensen, Section Chief, Reactor Projects
- R. Prevatte, Senior Resident Inspector
- Attended exit interview
2.
Onsite Followup of Licensee Failure to '.:tilize Personnel Monitoring
Equipment Correctly (92701)
On May 17, 1993, an NRC inspector was to accompany an auxiliary operator
(AO) during clearance activities to return "2B" Reactor Feed Pump to
service per clearance 2-93-00617. The cognizant A0 issued a digital
alarming dosimeter (DAD) to the inspector for use in accessing pcud
high radiation areas (HRAs) around the condenser. While at tha
" breezeway" control point checkin a Radiation Control Supervisor
responded to the control point and recognized the error in the A0
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issuing the dosimeter.
In accordance with E&RC procedures, only
Radiation Control personnel were authorized to issue dosimetry.
TS 6.8.1 requires that written procedures be established, implemented,
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and maintained covering the activities in the applicable procedures
recommended in Appendix "A" of Regulatory Guide 1.33, November 1972.
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E&RC Procedure, 0-E&RC-0352, Use of the ALNOR Dosimetry System,
Revision 2, dated May 1, 1992, Step 10.3.2.3, states that the Radiation
Control staff is responsible for assigning use of alarming dosimeters
only when the work environment is suitable for their use and when the
users have been instructed in proper use of the dosimeters and can be
trusted to use the dosimeters as instructed.
The inspector discussed the issue with Radiation Control and plant
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management and informed them that the failure of personnel other than RC
to issue DADS was a violation of procedure, 0-E&RC-0352 (50-325, 324/93-
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28-01).
During the May 17, 1993 accompaniment at the " breezeway" control point
check-in, the NRC inspector determined that neither the A0 nor the
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Radiation Control (RC) technician were familiar with the proper use of
the DAD. Neither individual could explain accurately to the inspector
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which of the two operating modes the DAD was operating in (dose rate or
dose accumulating), nor could either individual accurately identify what
the alarm set points were. The A0 could only assure that he knew to
leave the area it the DAD alarmed. It appeared to the inspector that
both individuals, the A0 and RC technician, lacked appropriate training
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in using the DADS.
Upon return to the control room, the inspector questioned a Senior
Reactor Operator (SRO) and A0 on how the DAD worked. The A0 did not
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know the alarm setpoints or that the DAD was in the dose accumulating
mode. The SR0 stated he was uncertain as to how the DAD functioned.
The licensee examined other DADS available for use in the A0's office
and found that four of the six in the charging-rack were set incorrectly
in the dose accumulating mode instead of the dose rate mode. The
licensee's immediate corrective action was to remove the DADS and
associated equipment from the A0's office until appropriate training
could be completed. The inspector found that the plant staff was given
brief training on DADS in a safety meeting in 1989, however no
subsequent training had been performed other than the direction given in
general employee training (GET).
Employees were taught in GET to
immediately leave the area and notify RC if the DAD alarmed.
10 CFR 19.12, Instructions to Workers, in part, requires that
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individuals working in or frequenting any portion of the restricted area
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shall be kept informed of radiation in such portions of the restricted
area, in precautions or procedures to minimize exposure to such
radioactive materials, and in the purposes and functions of protective
devices employed.
The inspector discussed the issue with RC and plant management and
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informed them that the failure to provide adequate information in the
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pm poses and functions of the DADS was a violation of
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P '.FR 19.12 (50-325, 324/93-28-02).
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The inspector reviewed all operations personnel cumulative dose for
1993, and noted that the data did not indicate that anyone had received
an unplanned exposure. However, the inspector identified the concerns
listed below to RC management.
The significance of this event can be explained by reviewing the
requirements of the Technical Specification (TS) requirements for access
to HRAs. In accordance with TS 6.12.1, a worker must have one of the
following three to enter a HRA: a dose rate meter which continuously
indicates the dose rate in the area; or a device which continuously
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integrates the dose and alarms when a preset integrated dose is
received; or an individual qualified in radiation protection procedures
equipped with a dose rate meter. Additional requiremerts for the second
option are that entry into the HRA be made only after udse rates in the
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area have been established and personnel have been made knowledgeable of
them; and for the third option the qualified individual must provide
positive control over the activities in the area.
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The A0 used a standing (generic) radiation work permit, RWP-002, which
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provided for entry to the general facility. This RWP was established
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exclusively for operations personnel, and it differed in comparison to
other RWPs.
It allowed entry by the A0 into HRAs and it did not require
the operator to obtain a pre-job briefing where radiation dose rates and
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hazards, if any, would be discussed. The inspector used RWP-1383 which
required a briefing by RC, a DAD set in the dose accumulating mode, and
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a dose rate meter.
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Concerns:
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(1)
The A0 entered a posted HRA (dose rates in the area due to
the power level did not reach 100 millirem per hour at
12 inches) with a monitoring device set for dose
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accumulation rather than dose rate monitoring.
(2)
Dose rates near the condenser can rapidly change during
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start up (dose rates up to 3,000 millirem per hour) and the
DAD was set on the dose accumulation mode which in TS option
2 requires that the entrant be knowledgeable of the dose
rates in the area. The A0 did not receive a pre-job
briefing on the radiation hazards in the area because his
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standing RWP did not require such, even though the RWP
allowed HRA entries into areas with changing dose rates.
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RC overlooked this important requirement when the A0 checked
in at the RC control point. After the confusion regarding
DAD use, neither the RC technician nor his supervisor
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required the A0 to review radiological survey results for
the posted HRA around the condenser.
Neither the RC
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technician or supervisor recognized the need to inform the
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A0 of the radiological hazards because his RWP did not
require it, even though he lacked adequate understanding of
the monitoring instrumentation.
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(3)
No formal training has been given to the operations
personnel on the issue or use of the DADS. In addition,
other than a brief paragraph in GET training and verbal
instructions during checkout of the DAD, no formal training
has been given to plant personnel. The GET training only
emphasized the correct response to an alarm, which was to
leave the area immediately and notify RC.
(4)
The licensee failed to conduct comparison tests with DAD and
dose rate instruments to determine the performance of the
DAD in high energy gamma and mixed radiation fields to
ascertain the instrument of preference.
(5)
The licensee investigation into the event was documented in
Minor Adverse Condition Report (MACR),93-147.
It did not
determine the root causes of the problem which appeared to
be failure to provide formal training on the use of DADS,
and deviation for operators, through waivers, from
established HRA controls and practices.
The MACR did not
identify the safety significance of the problem of operators
routinely using instruments set in the dose accumulating
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mode to monitor dose rates, which is not possible.
Additionally, the MACR did not identify a departure from TS
requirements, nor identify a complete recommended corrective
action and follow it through to completion.
Prior to the completion of the inspection, the inspector was
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informed that an Adverse Condition Report would be issued to
address these concerns.
3.
Licensee Event Report (LER) Review (92700'.
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(Closed) LER 325-92-01:
Inadequate leak testing of Iron-55 sealed
sources.
CP&L's Shearon Harris Nuclear Power Plant {SHNPP) issued LER l-91-020
which identified deficiencies in a radiation surveillance test used to
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leak test sealed sources to satisfy a TS requirement. The process
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included smearing the sources and analyzing the smears with an
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instrument capable of detecting 0.005 microcuries (uci) of contamination
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per test sample.
During a routine review of a completed test, an E&RC
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person noted a deficiency in the equipment / procedure used to detect the
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low energy emissions produced by Nickel-63 (Ni-63) and Iron-55 (Fe-55)
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isotopes. SHNPP personnel tagged the piece of equipment as being out-
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of-service and began sending their smehrs for this test to the Harris
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Energy and Environmental Control Center (HE&EC) for analysis.
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On January 5, 1992, the licensee reviewed the SHNPP LER and discovered
that they had the same deficiencies with their counting methods for
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smear surveys associated with sealed source leak tests. As at SHNPP,
the licensee determined that their gas flow proportional counter was not
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of a sufficient sensitivity to detect at least the 0.005 uti
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contamination limit for certain low energy emitting isotopes (Fe-55).
The licensee took the same corrective action as did SHNPP and is working
to correct the problem.
Procedural revisions have been initiated to identify isotopes to be
analyzed, their energy emission levels, and to add the requirement that
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the equipment used fcr the analysis have adequate detection
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capabilities.
The licensee determined their sources did not leak and
the safety significance of the event to be minimal, in that the source
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was contained inside the alloy analyzer in which it was being used.
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The inspector informed the licensee that although the LER would be
closed, the fai'ure to have an adequate procedure to comply with TS
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requirements for sealed source leak tests was a violation. However, the
viola. tion will be considered noncited because the licensee's efforts in
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identifyiag and correcting the violation meet the criteria specified in
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Section dII.B. of the Enforcement Policy (NCV 50-325,324/93-28-03).
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4.
Exit Interview
The inspector met with licensee representatives derated in Paragraph 1,
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at the conclusion of the inspection on June 4,1993. The inspector
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summarized the scope and findings of the inspection with licensee
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management and informed them of the two apparent violations and
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discussed them in detail.
The licensee was also informed of the NCV and
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closure of the LER. The inspector did not receive any dissenting
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comments, nor reviewed any documents or processes that were identified
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as proprietary.
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Item Number
Description and Reference
50-325,324/93-28-01
VIO - An auxiliary operator issued a DAD
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and was unauthorized to do so
(Paragraph 2).
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50-325, 324/93-28-02
VIO - The licensee failed to provide
adequate information to operations
personnel in the use of DADS
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(Paragraph 2).
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50-325, 324/93-28-03
NCV - The licensee identified and
corrected deficiencies with counting
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methods that were insufficient for
detecting low energy' emissions of some
isotopes (Fe-55) (Paragraph 3).
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