ML20133L593
| ML20133L593 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/09/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133L534 | List: |
| References | |
| 50-324-96-15, 50-325-96-15, NUDOCS 9701220073 | |
| Download: ML20133L593 (34) | |
See also: IR 05000324/1996015
Text
. _ .
_--
--
.
_-
.. -
-
. -
EXECUTIVE SUMMARY
Brunswick Steam Electric Plant, Units 1 & 2
NRC Inspection Report 50 325/96-15, 50-324/96 15
.
This integrated inspection included aspects of licensee operations,
'
engineering, maintenance, and plant support. The report covers a 6 we
period of resident inspection; in addition, it includes the results o
maintenance, in vessel inspections, and engineering inspections by r gional
inspectors.
ODerations
-
An unresolved item was identified concerning vessel di
ssembly while
secondary containment was inoperable.
(Section 01.1 . This was a
conscious action by the licensee although contrary
technical
specification requirements. This item was unreso ed pending further
review of the technical specifications and licen e's risk assessment.
An unresolved item was identified concerning
loss of shutdown cooling.
(Section 02.2).
Repairs were being
o n instrument rack that
contained the pressure switch to iso
es tdown cooling.
Further
review of the shutdown risk assess
w
being completed.
Maintenance
A noncited violation was id
fie concerning securing of wheeled
equipment and carts in the
(Section M1.1). The licensee
corrected the specific
b
nd revised their procedure.
~
Thealternateremotefiu
equipment and panels have been maintained
in a satisfactory map cr ept for the material condition of two main
RemoteShutdownPanels\\h'hwereconsideredpoor.
(Section M1.3).
The reactor ves
cr shroud ultrasonic examination efforts observed
by the inspector
conducted in an exemplified manner.
(Section
M2.1). Scan plans,
rocedures, personnel, and equipment were integrated
to obtain the bes
ossible inspection results.
In vessel visual
inspections were 1so performed in an effective manner.
Enaineerina
The licens
's progress to correct EQ program deficiencies was
satisfac ry. (Section E1.1).
No equipment operability issues were
identif' d.
An a arent violation was identified concerning exceeding the maximum
th
al power allowed by the license and a technical specification
t rmal limit.
(Section E2.1). This occurred due to inadequate testing
f the plant process computer after installation in 1994.
A repeat violation was identified concerning failure to take corrective
action to correct the cause of chlorine detector failures. (Section
E2.2).
Five out of eight detectors failed on September 19, 1996. This
9701220073 970109
ADOCK 05000324
0
J
_
._ _ _ _ _
. _ _
_ _ _ _ _ _ . - . _ _ _ _
.
.
__. _ _ _ .
,
i
EXECUTIVE SUMMARY
Brunswick Steam Electric Plant, Units 1 & 2
NRC Inspection Report 50 325/96 15, 50-324/96 15
This integrated inspection included aspects of licensee operations,
engineering, maintenance, and plant support. The report covers a 6-week
period of resident inspection; in addition, it includes the results of
maintenance, in-vessel inspections, and engineering inspections by regional
'
inspectors.
'
Operations
,
An unresolved item was identified concerning vessel disassembly while
secondary containment was inoperable.
(Section 01.1). This was a
conscious decision planned by the licensee with the belief that
technical specification requirements were met although secondary
containment was recuired to be maintained during refueling. This item
was unresolved pencing further review of the technical specifications
and licensee's risk assessment.
An unresolved item was identified concerning a loss of shutdown cooling.
(Section 02.2).
Repairs were being made to an instrument rack that
contained the pressure switch to isolate shutdown cooling.
Further
review of the shutdown risk assessment was being completed.
Maintenance
'
.
A noncited violation was identified concerning securing of wheeled
equipment and carts in the plant.
(Section M1.1). The licensee
corrected the specific problems and revised their procedure.
The alternate remote shutdown equipment and panels have been maintained
in a satisfactory manner except for the material condition of two main
Remote Shutdown Panels which were considered poor.
(Section M1.3).
The reactor vessel core shroud ultrasonic examination efforts observed
by the inspector were conducted in an exemplified manner.
(Section
i
M2.1).
Scan plans, procedures, personnel, and equipment were integrated
to obtain the best possible inspection results.
In vessel visual
inspections were also performed in an effective manner.
Enaineerina
The licensee's progress to correct EQ program deficiencies was
satisfactory. (Section E1.1). No equipment operability issues were
identified.
An apparent violation was identified concerning exceeding the maximum
thermal power allowed by the license and a technical specification
thermal limit.
(Section E2.1). This occurred due to inadequate testing
of the plant process computer after installation in 1994.
,
.
A repeat violation was identified concerning failure to take corrective
action to correct the cause of chlorine detector failures. (Section
E2. 2.) .
Five out of eight detectors failed on September 19, 1996. This
.s
ENCLOSURE 3
.
i
.
1
I
I
._
-- _ -.
-
_.
.-
-
-.
.
d
2
,
Enaineerina
The licensee committed to keep the unit at the old 100% power
vel
pending resolution of questions.
Plant Support
Overall, the licensee's program for monitoring externa exposure and
tracking dose within the restricted area was effectiv . (Section R1 &
RS).
However, outside the restricted area, the lic see's dosimetry
,
procedures did not adequately address occupational
oses to workers in
the controlled area who were receiving doses abo
the public dose
limit. One violation was identifie
failur to implement a
radiological control procedure cons;
t wit the requirements of 10
CFR 20.1502 (a)(2) which requires m
toring f dose to declared
'
pregnant women likely to receiv ad e in xcess of 500 millirem. One
l
unresolved item was open for t
nresolv
issue of accurate dose
"
tracking and assignment prac 'ces nd r ated procedures. One non cited
violation was identified f
ilure o the licensee to train workers
,
!
receiving occupational dose
ccor nce with the requirements of 10 CFR 19.12. Instructions to
rkers.
.
A fire protection mod ication a ociated with the deluge valves was
adequate. (Section F
The esign review failed to identify an
updated final safety
ysis eport discrepancy for internal flooding
in the reactor building.
,
i
a
,
4
1
a
_
_
_
__
_
_ _ . _ _ _
.
._.
.-
.
._
_ _ - -
. _
N
2
Enaineerino
a
The licensee committed to keep the unit at the old 100% power level
pending resolution of questiens.
Plant Support
d
Overall, the licensee's program for monitoring external exposure and
-
i
tracking dose within the restricted area was effective. (Section R1 &
RS). However, outside the restricted area, the licensee's dosimetry
.
procedures did not adequately address occupational doses to workers in
the controlled area who were receiving doses above the public dose
limit. One violation was identified for failure to implement a
radiological control procedure consistent with the requirements of 10 CFR 20.1502 (a)(2) which requires monitoring of dose to declared
pregnant women likely to receive a dose in excess of 500 millirem. One
unresolved item was open for the unresolved issue of accurate dose
tracking and assignment practices and related procedures. One non cited
violation was identified for failure of the licensee to train workers
receiving occupational dose in accordance with the requirements of 10 CFR 19.12. Instructions to Workers.
-
1
The radiological controls program was being effectively implemented with
good occupational exposure controls demonstrated during outage
conditions. Internal and external exposures were being maintained to a
small fraction of regulatory limits. The ALARA program was reducing
total site dose but overall site dose remains relatively high. The
licensee has e:,perienced a high level of personnel contamination events
during 1996 year to date but a significant reduction in PCEs was noted
during the Unit 1 Fall outage was noted. Hinor discrepancies in
radioactive raterial labeling and control were observed while onsite
which were promptly corrected by the licensee.
A fire protection modification associated with the deluge valves was
adequate. (Section F2.1). The design review failed to identify an
updated final safety analysis report discrepancy for internal flooding
in the reactor building.
.
.
_
-
_
-____
_
.
2
1
12
bottom of the cabinet were checked and found properly sealed.
he
,
inspection reviewed the WR/JO for the task.
No deficiencies ere noted.
c.
Conclusion
The inspector concluded that the work observed on the
was in
accordance with the instructions provided to provide
aling protection
from a possible HELB. This WR/JO was one of many to orrect EQ material
condition problems with the MCCs in the reactor bu' ding for both units.
'
IV. Plant Support
,
R1
Radiological Protection and
istry Contr s
4
R1.4 External Occupational Exoasu
trol a
Personal Dosimetry
\\
a.
Insoection Scope (83724)
The inspectors evalu
the adequ y of the licensee's program for
monitoring external
tional
posures during normal operations and
the adequacy of the
n ee's
rsonal dosimetry program.
Emphasis was
!
given to the lic
ee' monito ng of occupational dose in buildings
close to but out
e res icted area fence that are within the
licensee's contr
area.
'
b.
Observations
dino
x
The inspec ors review
area Thermoluminescent Dosimeter (TLD) results
for the
ido Ja ary 11, 1996, through October 10. 1996, with focus
j
on exposure in ui dings occupied by personnel adjacent to the
licensee's re ri ed area boundary fence. A review of these iLD
'
results average for a 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> work year indicated several work areas
.
outside the fe e with elevated doses above the regulatory public dose
limit of 100
llirem aer year.
Doses for an average work year were
found to ra e from a ligh of 229 millirem on the second floor of the
Administra ve Building to doses under 100 millirem in the TAC Building.
The elev ed doses above the public dose limit were primarily
i
attribu ble to N-16 Turbine Shine resultant from the licensee's use of
5
Hydro n Water Chemistry. The licensee's area TLD monitoring network
conf' med that doses to workers were the highest for those workers whose
,
off'ces were the closest to the source (Turbine Building) as might be
e ected. Doses above the public dose limit were identified in the
ministrative Annex (Old Training) and Document Control Buildings
although these doses were less on average than those doses in the
Administrative Building. The inspectors review of licensee dosimetry,
monitoring, and general radiation control procedures indicated the
licensee did not treat dose to occupational workers in these buildings
in the controlled area as occupational dose and licensee procedures were
generally deficient in this regard. However, as defined in the
regulation, dose above the public dose limit which is received by a
worker in the course of employment during which the worker's assigned
____
_
_
__
__
.
.-
-
-
13
duties involve exposure to radiation from licensed sources is
occupational dose. The licensee was aware that some workers
tside of
the restricted area were receiving occupational doses above
e public
dose limit incidental to their occupational activities bas
on limited
data contained in a dosimetry technical report (95 08) da d August 28,
1995. However, this report failed to address the issue omprehensively
other than to conclude that no workers exceeded the 50 miiiirem
monitoring threshold based on an analysis of actual i dividual summed
'
doses inside and outside the restricted area during id 1995 and,
,
therefore, there was no regulatory requirement for he monitoring of
-
individuals in the controlled area.
1
The inspectors reviewed available dose data f
radiation workers
.
outside the restricted area and determined t t no workers were
exceeding regulatory limits.
However, the
spectors reviewed dose
monitoring procedures as w
as dose rec ds of other categories of
,
individuals including memb
f the pub
c, casual visitors, and the
i
exposure monitoring prac i
ocedur
for declared pregnant women and
<
the embryo / fetus.
No c ce
s were i
ntified with respect to public or
casual visitors. Howeve , bec)use t
regulatory limits for declared
pregnant women are at n tenth of ccupational dose limits for ex30sure
and monitoring the ' 1p
ilatio of declared pregnant women at t1e
site was reviewed flr he p ior wo years. Of this population of
workers none were ir
ied t t exceeded regulatory limits with
respect to radi
'on
xposur . A review of licensee actions with
respect to decl
hr nan women indicated the licensee had taken
actions with res
t to t se workers post pregnancy declaration to
minimize occ
1 ex sure.
Licensee actions included reassignment
of workers t
e
dose 'ntensive duties to lower their exposures.
However, t e 1
nsee as not monitoring declared pregnant women who
were worki g in he
ntrolled area and had no procedural provision for
declared
e a
men who may work in buildings with exposure levels
above pub i
e imits. These workers, based on a review of area TLD
monitoring res 1 s for office space located in the controlled area, have
potential to r eive during a nine month gestation period doses in
excess of the 0 millirem occupational dose limit at which monitoring is
required.
though no declared pregnant women were identified who would
actually e eed the 50 millirem monitoring limit based on specific
declarat' n dates and remaining periods of pregnancy, the workers
reviewe approached the limit (maximum prospective dose was 43 millirem)
indic ing the need for monitoring as a conservative measure.
Inc' dental to this review the inspectors identified a defect with
r pect to the applicable procedure for dosimetry issuance for the
nitoring of declared pregnant women. Carolina Power & Light Company
iuclear Generation Group Standard Procedure DOS NGGC 0002 " Dosimetry
Issuance" Revision 1 Effective Date August 12, 1996, states within
paragraph 9.9.5. Individual Monitoring of Declared Pregnant Women, "If
the woman works solely in the controlled area (does not enter the
restricted area), then individual monitoring is not required if the dose
is not likely to exceed 100 mrem in a year, the public dose limit."
This procedure directly contradicts the requirements of 10 CFR 20.1502
.
.-
-
-
14
(a) (2) which requires licensees to monitor exposures to radiati n for
declared pregnant women likely to receive in one year from sou _es
external to the body a dose in excess of 50 millirem. The fa' ure to
implement a radiological control procedure consistent with
e
requirements of 10 CFR 20.1502 (a) (2) is a violation of r ulatory
recuirements (VIO 50 325(324)/96 16 02), Failure to Impi
ent a
Raciological Control Procedure Consistent with 10 CFR 2 .1502 (a)(2).
The inspectors evaluated the licensee *s procedures a
practices with
respect to the monitoring and tracking of occupatio 1 dose for
radiation workers. The licensee was unable to de nstrate adecuately
during the period of inspect'
that occupationa dose receivec by
workers in the controlled arha
s being consi
red in the prospective
analysis used to determine if
rs require monitoring in accordance
with the requirements of 0
1502.
Ra ation workers who are
required to be monitored or r iation wor in restricted areas, i.e.,
workers who are likely t receive greater han 500 millirem in a year
based on a prospective na sis of likel
dose, are also required to be
monitored for occupati nal
e receiv
in controlled areas. The
licensee was unable
oduce recor
or reference procedures which
demonstrated full c
ce with t
requirements of 10 CFR 20.1502 for
monitoring occupati
exposure.
ditionally, the licensee was asked
to demonstrate, as co
rvative
radiological safety and within
regulatory re i
.ts, the cu ent dosimetry practice of subtracting
100% of turbi
ine dose fro the sitewide personnel TLDs stored in
racks at the entr ces to th restrict
area. The inspectors stated to
the licens
that t 's prac ce ap)earee ..anconservative with respect to
the accura
ing of ose bot 1 in terms of cumulative site dose and
individual
e assignme
s.
The licensee was unable to provide any
data to demons ate thi
practice as conservative or reasonable during
the wee of insp tio .
A subtraction of less than 100% of the turbine
shine
se oul
be
reasonable approach in the view of the inspectors
due to
fac th
most of the TLDs actively in use are typically on
personnel 1
e
e restricted area for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> or more during a
usual workyea .
he subtraction from worker dose assignments of the
full turbine s ne dose component as detected on the area TLDs in the
vicinity of t.
TLD racks (which includes the turbine shine dose workers
receive whi
working in the restricted area and while wearing their
TLDs) does at appear reasonable.
Subtracting the turbine shine dose
componen incurred by radiation workers during normal working hours when
the TLD are being worn by the radiation workers is not clearly
justif'able or conservative with respect to dose assignment practices.
The icensee indicated further evaluation and time to prepare a response
w
necessary due in part to the need to coordinate a response with
rporate dosimetry personnel who worked offsite in the Harris Energy
and Environmental Center at New Hill, N. C.
These inspector concerns
were unresolved at the end of the inspection and will require further
evaluation of licensee data. These issues regarding demonstration of
accurate and reasonable dose tracking and dose assignment practices and
related procedures were identified to the licensee as Unresolved Item
_
_
_
. _ .
.
15
(URI 50 325(324)/96-16 03), Unresolved Item for Lack of Accurate ose
Tracking and Dose Assignment Practices and Related Procedures.
c.
Conclusions
The licensee's program for monitoring external exposure a
tracking
dose within the restricted area was determined to be eff tive. The
licensee requires by procedure all radiation workers e ering the
1
restricted area to be monitored by TLD and all worker entering the RCA
to be monitored with electronic dosimetry as well.
e monitoring of
-
all workers inside the restricted area by TLDs for ose of record
pur>oses exceeds regulator requirements in that
ly a fraction of the
wor (ers who actually enter
restricted area u
1 exceed the 500
millirem threshold requiri
itoring. Outs' e the restricted area,
however, licensee dosimetr
rocedures were
icient in that the
'
monitoring and tracking f
pational dos in the controlled area was
not adequately address
in procedure.
Sp ifically, procedures which
require monitoring of o
in the control ed area for workers who are
.
required to be monito di
the restric d area and practices for
'
adjusting radiatio
rker dose assig ents to eliminate all turbine
shine dose were id
ied to the li
nsee as issues requiring further
evaluation by the
and proc ural treatment as appropriate.
These issues are an
esolved It
with respect to dose tracking,
assignment of
and related
ocedural improvement. One violation
was identified f r a osimetry
suance procedure which allowed declared
pregnant women 1
the control
d area to go unmonitored for prospective
radiation d e abo
50 mill' em contrary to the requirements of 10 CFR 1502 (a) (
.
!
R5
Staff Trpni
Qualifi tion in Radiation Protection and Chemistry
R5.1 Trainina oi Radiation orkers
a.
Insoectio
De (
50)
The inspectors
aluated the adequacy of training of radiation workers
who were recei
ng occupational exposure consistent with the
,
requirements or training contained in 10 CFR 19.12. Also evaluated
were the qu ifications of a recently assigned Radiation Protection
Manager to etermine if all qualification requirements were satisfied
consiste
with Technical Specification 6.3.1 and Reg Guide 1.8.
b.
Observ ions and Findinas
'
The nspectors determined that workers in the licensee's controlled area
a
outside the restricted area were receiving occupational dose as
fined in 10 CFR Part 20 (also reference above Paragraph R.1.4.b.).
he intent of the training requirement of 10 CFR 19.12. Instruction to
Workers, is that individuals who are permitted to receive occupational
doses within occupational limits will receive appropriate training
commensurate with associated radiological risk.
Furthermore, < hen doses
received by workers are in fact occupational dose, appropriate
__
_
_
__
_
_
4
16
instructions should inform the worker that he/she is subject to
occupational dose limits rather than public dose limits.
Plant orkers
have the right to be fully informed as to radiological hazards nd
conditions of their workplace in order that they may make inf rmed
decisions related to matters such as
d the
minimizing of occupational exposure. pregnancy declaration
The inspectors deter ined through
a review of training material and related quizzes that t
intent of 10 CFR 19.12 training was met by the licensee's Radiation orker Training
course. The radiological training content of the lic see's Plant
Access Training was minimal, did not meet the intent f 10 CFR 19.12,
and was not sufficient to provide training commens ate with risk as
4
specified in regulatory guidanc
In order to en re that workers who
were receiving occupational dos
trained i
accordance with 10 CFR 19.12, the inspectors reviewed
ining record for a large sample of
workers whose normal work s tion were in bu~ dings in the controlled
'
area. Through this review
was determine that one or more workers
,
receiving occupational dos h
not been t ined in accordance with 10 CFR 19.12. These workers ithe current 1
were receiving or aotentially
could receive occupational dose that re ired the workers to
1 ave
.
radiaticn worker traini
e failure f the licensee to have trained
all workers who were re
occup ional doses was determined to be a
violation of the require
qts of 10 FR 19.12. Although this violation
of regulatory requ
ents was NR identified the violation will not be
cited due its isol
re an relatively low safety significance.
The licensee commi
to trai
he workers affected in accordance with
10 CFR 19.12 an commi
d to pgrade training for all workers in the
controlled arc
.
would nsure that they were aware of the
occupational c
being r eived to include a characterization of
associated radio
ical r' ks, and to conduct a review of rad worker
training a quacy in ge ral to ensure that the full intent of 10 CFR 19.12 was
ing met fo all workers receiving occupational exposures
both in r
r4te a
controlled areas. The failure of the licensee to
train all wo
r i
accordance with the requirements of 10 CFR 19.12,
Instruction to
r rs, constitutes a violation of minor safety
significance and s being treated as a Non-Cited Violation, consistent
with Section IV f the NRC Enforcement Policy (NCV 50-325(324)/96-16-
04), Failure
Train Workers Receiving Occupational Dose in Accordance
with 10 CFR
.12.
A qualifi
tion review was conducted for a recently assigned Radiation
Protecti
Manager (RPM) to determine if the individual assigned
posses d the necessary qualifications for the position. Qualification
requi ments, as committed to through the licensee's Technical
Spe
ication 6.3.1, specify that the RPM will meet or exceed the
cu ifications outlined in Reg Guide 1.8. which include a bachelor's
c
ree in science or engineering and five years experience in applied
adiation protection.
s
17
c.
Conclusions
Although the licensee was adequately training workers who work n the
restricted area in accordance with 10 CFR 19.12. Instruction
Workers,
the ins)ector identified a noncompliance with 10 CFR 19.12 i that not
all wor (ers who were receiving occupational dose were trai
d in
accordance with 10 CFR 19.12.
Specifically, examples of orkers in the
controlled area were identified who were receiving occu tional dose but
who were not trained in accordance with 10 CFR 19.12.
his violation
will be treated as a Non Cited Violation consistent
th Section IV of
A qualification review of an 1
i
al recently ssigned as Radiation
Protection Manager conclud
th individual wa sufficiently qualified.
F2
Status of Fire Protectio
ilities and Eq pment
F2.1 Fire Protection Desian Chance and Plant
difications
a.
Insoection Scope (71;
04)
The inspector review
e adequac of s design change to a number of
plant automatifY1 -
pression
stems associated with ESR 94 00345.
The inspector
1 ed down the pl nt areas affected by the change to
inspect the imp
ntation of
e modification in the field and observed
portions of post mo 'ficatio
- esting.
b.
Observatii
ndinas
'
L
'
The ins ector eviewed
plementation of ESR 94-00345. The purpose of
i
this m dificati
was o decommission the Automatic Sprinkler
Corpo tio "Model C". 3 rimed preaction deluge valves by removal of the
clappe ,
nka
s.
atcling arm and sealing diaphragm. and sealing the
valve dia ra
o ning with a cover plate. This type of valve had been
experiencin
e rring failures including the inability to reset the
latching arm a
re)eated rupturing of the latch arm diaphragm seal.
Failure of t
diaparagm seal resulted in continuous water leakage to
the floor a a near the valve assembly. This modification effectively
eliminate
he preaction valve function and converted the preaction
i
system t a full flow net pipe sprinkler system design.
'
The m ification involved changes to the following fire suppression
sys
deluge valves:
actor Buildinas
1 FP DV319.
2-FP DV319
i
18
Diesel Generator Buildina
2-FP DV15,
2 FP-DV18
2 FP-DV19
Service Water Intake Buildina
2 FP DV21,
1 FP DV22, 2-FP DV2,
Radwaste Buildina
2 FP DV704
The licensee's engineer revi ed the inter al flooding analysis and
calculations for the R ctor Buildings, D' sel Generator Building,
Radwaste Building, and
vice Water Bui ding and concluded that due to
the physical separati
o
edundant s ety-related equipment in the
Reactor Buildings
docum ted conc sions of previous flooding
analysis, the modi
'on did not
ter these analysis nor the
redundancy of the
The in ector reviewed the history and
assumations for the
fication nd the 10 CFR 50.59 Safety Evaluation
for t7e chang
and d
rmined
at they were adequately evaluated. No
unreviewed sa e
c
erns wer found, however, the inspector identified
a UFSAR discrep
as ociat
with flooding protection in the reactor
buildings.
UFSARSecho
2.1 st es that Class I Motor Control Centers and
.
instrument n ks i the reactor buildings, when near (water) leakage
source , were
vide with drip shields to minimize damage.
During the
walkd n f areas of he reactor buildings where automatic sprinkler
prote i
is rovi ed the inspector identified that Class I instrument
racks H
0
on he 20' elevation and H21-P014, P017. P018, and P022
on the -17
lev ion were not provided with drip shields.
In some
cases sprinkler heads and piping were installed within five feet above
these instrum t racks. Additional licensee walkdowns of other reactor
,
building el
ations indicated that dri) shields had not been installed
,
over any o the Class I instrument rac(s within areas provided with
automati
et pipe sprinkler systems in the RBs.
After
scussions with the licensee, Condition Report CR 96-03943 was
issu
to track the failure to provide dri) shields over Class I
ins" ument racks near leakage sourcas in t1e reactor buildings. This
UF AR discrepancy was identified by the inspector, and is discussed in
ction F2.2.
A review of post modification testing for modification ESR 94 00345 was
performed to confirm that appropriate National Fire Protection
Association hydrostatic test pressures and duration had been specified.
i
On November 25, 1996, the inspector observed the successful hydrostatic
testing for a deluge system protecting the diesel generator building.
No discrepancies were identified.
1
l
19
c.
Conclusions
The inspectors concluded that the design change and plant
difications
of the deluge valves were adequate, however, the design r view failed to
identify an UFSAR discrepancy associated with internal
ooding in the
reactor building.
F2.2 Soecial UFSAR Review
A recent discovery of a licensee o>erating the f ility in a manner
contrary to the UFSAR description lighlighted t
need for a special
focused review that compa e
ant practices,
rocedures, and/or
parameters to the UFSAR d ser
ons. While erforming the inspections
discussed in this report,
ins ectors re ewed the applicable
portions of the UFSAR
at
ated to the reas inspected. The
inspectors verified t t the
SAR wordi
was consistent with the
observed plant practi e
procedures, a d/or parameters.
The licensee start
revie of the FSAR on July 1,1996. After the
,
first quarter of r vie , the licens e had written 23 condition reports
'
for 70 discrepanci
Th
number of problems indicated a programmatic
problem with maintai
the UFS
current.
The inspectoH
ction 3.4.2.1, as part of the fire
protection ES
ification alkdown activities. An inconsistency was
noted in that the
censee ailed to provide drip shields over Class I
instrumen
c
near lea ge sources in the reactor buildings. This
issue is
sse in Se ion F2.1. This item will be identified as
part of URI
(324)/9 05 02.
V.
Manaaement Meetinas
XI
Exit
elina[umm
v
The ins
esented the inspection results to members of licensee
management at he conclusion of the inspection on Decemh? 12, 1996. On
December 19 1996, the licensee was informed that
3revious unresolved
item 325/9 15 02, Loss of Shutdown Cooling, was clanged to violation
325/96-16 1 discussed in this re) ort.
Post inspection briefings were
conduct
on November 7 and Decem)er 6, 1996. Tne licensee acknowledged
the fi
ings presented.
The icensee did not identify any materials used during the inspection
as roprietary information.
___.__.
_
_ _ . _ _ - . ~ . _ .
.
20
PARTIAL LIST OF PERSONS CONTACTED
Licensee
G. Barnes, Manager Training
C. Barnhill, Dosimetry Supervisor, E&RC
A. Brittain Manager Security
W. Campbell, Vice President. Brunswick Steam Electric P1
t
R. Crate, Radwaste Upgrade Project Manager
B. Deacy, Outage Manager
N. Gannon, Manager Maintenance
'
J. Gawron, Manager Nuclear Asses m
W. Icenogle, Corporate Dosimetry Ha
's Energy & nvironmental Center
W. Levis, Director Site Operat' r
R. Lopriore, General Plant Ma ger
J. Lyash, Brunswick Engineer g Supp t Secti
J. McGowan, Senior Speciali
, Regulatory Af irs
B. Nurnburger, Superintend
t,
vironmenta and Chemistry
C. Pardee, Manager Opera
ns
P. Sawyer, Acting Super ~ te ent, Radiat' n Protection
R. Schlichter, Manager
v' o
ntal a
Radiation Control
S. Tabor, Senior Speciali - Regulato
Affairs
J. Terry, Program
yst,
RC
J
M. Turkal, Supervi
~
nsing an
egulatory Programs
H. Wall, Training
rvis
1
Other licens
ees r co ractors included office, operation,
maintenance,
e str
radia on, and corporate personnel.
E. Brown
M. Janus
i
C. Patter on
W. Ranki
G. Wiseman
__ .
_ _ -
_ _ _
_ _ _ _
_ _ - _ -
t
21
INSPECTION PROCEDURES USED
IP 37551:
Onsite Engineering
IP 40500:
Effectiveness of Licensee Controls in Identifying.
esolving, and
Preventing Problems
IP 61726:
Surveillance Observations
IP 62707:
Maintenance Observations
IP 71707:
Plant Operations
IP 71714:
Cold Weather Preparati
IP 71750:
Plant Support Activiti s
IP 83724:
External Occupational
o
Control
d Personal Dosimetry
IP 83750:
Occupational Radiati n
sur During ower
IP 92901:
Followup - Operatio
ITEMS OP
D. CLOSED,
DISCUSSED
Ooened
50 325(324)/96 16-01
V
reper ork Planning Resulted in a loss of
Shu dow Cooling (Paragraph 02.1)
50-325(324)/96 16 0
0
Fail
e to Implement a Radiological Control
Pr edure Consistent with 10 CFR 20.1502 (a)(2)
(
ragraph R1.4)
50 325(324)/96
6-
Unresolved Item for Lack of Accurate Dose
Tracking and Dose Assignment Practices and
Related Procedures
(Paragraph R1.4)
50 325(324 96-
-04
Failure to Train Workers Receiving Occupational
Dose in Accordance with 10 CFR 19.12 (Paragraph
R5.1)
Closed
50 325/96 15-
Loss of Shutdown Cooling (Paragraph 08.1)
Discussed
50-325( 4)/96 05 02
UFSAR Discrepancies (Paragraph F2.2)
1
._.
._
. _ .
_
_._ _ ._. _
._ _ _
.
_
_
. _ .
_.
._
,
,
12
bottom of the cabinet were checked and found properly sealed. The
,
inspection reviewed the WR/JO for the task. No deficiencies were noted.
c.
Conclusion
f
The inspector concluded that the work observed on the MCC was in
'
accordance with the instructions provided to provide sealing protection
from a possible HELB. This WR/JO was one of many to correct EQ material
condition problems with the MCCs in the reactor building for both units.
'
IV. Plant Support
'
!
!
R1
Radiological Protection end Chemistry Controls
4
R1.1 General Radioloaical Controls
,
a.
Insoection Scope (83750 & 83729)
The inspectors evaluated the adequacy of the licensee's general
radiological controls program with em)hasis on exposure controls during
'
outage operations, adequac.y of pre jo) health physics planning and
briefings, effectiveness of the Radiation Work Permit (RWP) process,
i
adequacy of current radiological surveys to support work activities, and
the adequacy of Radiation Control (RC) Technician staffing for coverage
of ongoing work.
1
t, . Observations and Findinas
The inspectors evaluated general controls for radiological exposures,
such as the Radiation Work Permit (RWP) process, radiation surveys, and
pre job briefings, to determine if they met applicable regulatory
requirements and were designed to maintain exposures As Low As
Reasonably Achievable (ALARA). The inspectors reviewed several RWPs
utilized to control ongoing outage work within the radiologically
controlled area (RCA), including high dose activities, and noted that
the rad controls observed were appropriate for the described tasks and
radiological conditions. Several specific RWPs were reviewed to
l
determine if the supporting radiological survey data was current and
,
sufficient to support work to be conducted under the RWP. No
,
discrepancies were noted. Radiological control requirements specified
for the specific RWPs reviewed were determined to be adequate for the
work scopes identified for each of these RWPs. The licensee utilizes
special RWPs for specific plant locations and tasks primarily involving
higher doses and for tasks needing more complex radiological controls.
General RWPs are used for work not requiring as stringent radiation
controls and are used for routine job coverage and are not valid for
entry into very high radiation areas.
The inspectors reviewed the RWPs being utilized on the refuel floor for
general maintenance tasks, routine job coverage, and inspection
activity. Based on the inspectors review of these RWPs and discussions
I
--
- , .
13
with licensee personnel, the inspectors determined that the broad scope
radiation work permits being utilized for general refuel floor work were
appropriate and adequate for the tasks that were permitted under these
RWPs.
Specific tasks to be conducted on the refuel floor with
significant radiological hazards and requiring special radiological
controls require a special RWP. The licensee was able to demonstrate
that appropriate RWPs had been prepared for those situations requiring a
special RWP in accordance with licensee procedure Environmental and
Radiation Control
(E&RC) 0230, " Issue and Use of Radiation Work
Permits" (Revision 33). No discrepancies in implementation of the
licensee's RWP procedure or with regulatory requirements were identified
during this evaluation of the licensee's RWP practices.
3
The inspectors evaluated the adequacy of the licensee's pre job briefing
program to ensure that ALARA/ Radiation Control Briefings were in full
compliance with the licensee's E&RC-0045 Procedure Revision 5,
"ALARA/ Radiation Control Pre Job Briefings" and were conducted in a
manner fully sufficient to address radiological concerns of ongoing
work. The inspectors attended pre job briefings during this inspection,
'
and had attended additional pre job briefings during earlier 1996
inspection activity at BNP. The inspector consistently observed
thorough and indepth pre job briefings sufficient to minimize
unnecessary exposure and to identify radiological risks to radiation
workers. Also observed during these briefings was good specific
planning as to how to minimize personnel exposure as well as good
planning of the specific tasks to be conducted with full consideration
of ALARA objectives. Without exception, for the pre job briefings
attended, good work evolution planning and good "What If?" questioning
as to the work process and adequacy of radiation controls was observed.
No procedural discrepancies were identified during observations of pre-
job briefings.
The inspectors evaluated the adequacy of the licensee's radiation survey
program to ensure that sufficient surveys were being conducted at the
needed frequency to identify potential radiological hazards that may be
present. The inspectors selected at random a broad sample of current
surveys on file in the Radiation Control Office and evaluated the
surveys against the requirements of Procedure E&RC-0100," Routine /Special
Dose Rate Survey", Revision 24. The representative surveys selected for
review were surveys of areas in the reactor buildings, turbine
buildings, and radwaste building and included specific areas such as the
Unit 1 & Unit 2 Tip rooms. Several of the specific area surveys reviewed
were selected in advance in order to determine that current radiological
surveys were readily avdilable and accessible to radiation workers and
RC Technicians in order to support emergent work evolutions as needed.
All surveys selected were available to the inspectors in the Radiation
Control Office files although procedurally the licensee has no
requirement to store these survey records in this location.
Each of the
selected surveys was determined to be in compliance with the licensee's
procedure with respect to being up to date, of adequate detail and
completeness to fully characterize radiological hazards, and sufficient
.- . - - -
.
_ _ _
-.
__
-
-.
.
. . . .
-
,
14
and current to support work planning needs with no discrepancies noted.
.
The inspectors reviewed the licensee's current organization and staffing
levels as they related to maintaining an effective Environmental and
Radiation Control organization in support of plant activities Within
the Radiation Protection subunit there were 47 currently authorized
Radiation Control Technician positions although there were six vacancies
'
at the time of the inspection which the licensee is not currently
planning to fill. The licensee is currently su)plementing this
<
organization during peak workload periods, suc1 as an outage, with
shared resources from other licensee sites as well as with contract
technician support. During plant walkdowns, to include observation of RC
,
Tech coverage at the primary RCA access point and coverage on the spent
'
fuel pool floor, the inspectors observed the utilization of RC
'
Technician resources and determined that appropriate numbers of RC
personnel were being employed to ensure adequate job coverage and
1
adequate E&RC procedural adherence during heightened outage levels of
work activity. The inspector evaluated the overall adequacy of
operational RC Technician coverage and determined that adequate shift
,
coverage was available to support operational requirements with no
concerns noted.
c.
Conclusions
Implementation of the radiological control areas of RWP processes,
radiation surveys, pre job briefings, and Radiation Control Technician
staffing met regulatory requirements.
R1.2 Specific Radioloaical Controls
a.
Inspection Scope (83750 & 83729)
Specific radiological control areas inspected included internal and
external exposure controls, locked high and very high radiation area
controls, radiation area postings, contamination area training
corrective actions, and labeling of radioactive material.
b.
Observation and Findinas
The inspectors made frequent tours of the radiologically controlled area
(RCA), observed compliance of licensee personnel with radiation
protection procedures for high dose outage work evolutions, and
conducted interviews with licensee personnel with respect to knowledge
of radiological controls and working conditions.
During plant walkdowns within the RCA, the inspectors conducted brief
interviews at random with radiation workers inside the RCA. The
interviews were conducted with radiation workers of various discialines
in order to determine the level of understanding of radiation wor (
permit (RWP) requirements from a representative cross section of plant
workers. All of the workers interviewed were verified to have signed
-.
- - . - - .
- -
. . - . . . - _ - .
. _ - - -
-
-
.
.--_
- . . ,
j
i
,
2
!
15
i
-
I
onto an RWP, were wearing electronic dosimetry appropriate to their work
.
activities within the RCA in accordance with plant 3rocedures, and were
i
performing specific work activities on appropriate RWPs. The questions
asked included the RWP number of the RWP signed in on, electronic
dosimetry dose limits, and general radiological working conditions for
the areas worked in. For the workers interviewed, a good knowledge of
RWP requirements and a good knowledge of radiological working conditions
was demonstrated.
The inspectors reviewed total whole body exposures for all Brunswick
Nuclear Plant (BNP) radiation workers and determined that all whole body
l
l
exposures assigned since the beginning of the SALP cycle (5/14/95)
through the end of this inspection were within 10 CFR Part 20 limits. A
,
i
review of licensee personnel exposure records indicated the following
maximum individual exposures at the plant during this period: Total
,
Effective Dose Equivalent (TEDE): 2212 mrem: Committed Effective Dose
>
Equivalent (CEDE): 92 mrem: and Shallow Dose Equivalent (SDE) whole
body: 2212 mrem. The inspectors determined the licensee had adequately
,
!
monitored and tracked individual occupational radiation exposures in
i
accordance with 10 CFR Part 20 requirements and that all doses reported
j
were at a small percentage of applicable regulatory limits.
The inspectors reviewed and discussed with licensee representatives the
j
arogram for controlling access to high radiation areas (HRAs), locked
,
ligh radiation areas (LHRAs), and very high radiation areas (VHRAs).
Control of these areas was also inspected during tours for proper
posting and access controls. No HRAs, LHRAs, or VHRAs were identified
1
where required posting were needed but not posted. Areas controlled as
LHRAs were found locked in accordance with licensee procedure. The
!
licensee had completed a posting u) grade with respect to radiation areas
to achieve full conformance with t1e regulatory intent of 10 CFR
20.1902. The inspectors noted significantly upgraded and improved
l
posting practices throughout the plant.
!
Key controls for entry into locked and very high radiation areas were
evaluated against the requirements of the licensee's administrative
control procedure. Appropriate keys were controlled in accordance with
i
procedure. During a tour of the Unit 1 Spent Fuel Pool area the
l
inspectors observed end of outage clean up and decontamination
i
activities. Good radiological controls were in place in this area
'
overall. A comprehensive sample of survey instruments and respirators
l
available for issuance were inspected and all were determined to have
current calibration dates. Radiation workers during peak traffic
periods were observed exiting the RCA in accordance with procedures for
i
frisking out of the RCA to include properly clearing small articles with
the small articles monitor.
i
During tours of the plant, the inspectors observed HP technicians
performing radiation and contamination surveys in accordance with
'
procedure. Also, during inspection of the tool issuance rooms good
1
controls for slightly contaminated tools inside the RCA and for clean
tools outside the RCA were noted.
i
J
_ . _ .
,
_
_ . _
!
!
i
16
During a walkdown of the RCA near the scaffold warehouse a yellow rad
material bag containing used protective clothing, laundry bags, and
miscellaneous trash was found by the inspectors unlabeled and
unattended. Also, a nearby dumpster located on the west side of the
fabrication shop was found by the inspectors to contain green bags with
1
purple tools indicative of fixed contamination in them. The container
j
was designated for clean radioactive waste and was unlabeled. All
1
material was later surveyed and determined to be less than 100 cpm over
background and, therefore, no label was required by regulation
'
(exemption for less than Appendix C per 10 CFR 20.1905 (a)) or by
licensee procedure. However, control of the materials was below normal
plant rad material control standards and the licensee initiated a
radioactive material control condition report and promptly corrected the
deficiencies. Also, outside the RCA between the radwaste building and
the diesel generator building, one rad material label on a concrete
vault containing resins was identified as labeled in minimal compliance
with 10 CFR 20.1904. The licensee corrected this isolated example of a
minimally sufficient label with the addition of an increased description
of material contents.
c.
Conclusions
.
The radiological controls program was being effectively implemented.
Good occupational exposure controls were demonstrated during outage
conditions. An upgrade in radiation area posting throughout the
facility was evident. Minor discrepancies in radioactive material
control were identified and corrected.
R1.3 Contamination Controls
.
a.
Insoection Scope (83750)
The inspectors evaluated the licensee's personnel contamination events
(PCEs) experience and the adequacy of corrective actions and related
followup. Also evaluated was the adequacy of contaminated area controls.
b.
Observations and Findinas
During the Unit 1 Fall outage through November 6, 1996 the site had
incurred 52 Personnel Contamination Events (PCE) which was substantially
less than the initial Unit 1 outage goal of 71. This superior PCE Unit 1
outage performance was noteworthy due to the relatively high number of
PCEs experienced by the licensee earlier in 1996 primarily during the
Unit 2 outage. The licensee significantly exceeded the Unit 2 PCE
outage goal of 81 during the Spring 1996 outage by approximately 200
percent necessitating a revised annual PCE goal of 320. As of the date
of this inspection the licensee was achieving much improved PCE
performance relative to the earlier 1996 Unit 2 Spring outage
performance and the revised goal should be met at year end. The
inspectors evaluated the licensee's PCE reduction initiative and
identified several contributors to the improved PCE performance to
-
.
_
.
i
r
17
include: 1) Increased work group ownership for PCE goals: 2) Improved
training to include develoament of Double Step Off Pad training: and 3)
Increased and more prompt E&RC management oversight for each PCE
i
occurrence. The inspectors also selectively reviewed the higher assigned
dose PCE reports and noted no assessment or procedural errors. Where a
skin dose assessment was required by licensee procedure based on the
level of skin activity in corrected counts per minute, the inspectors
were able to verify the assessment had been performed as per procedure
with conservative dose assessment methodology utilized.
c.
Conclusions
Although the licensee experienced a high level of personnel
contamination events through 1996, significantly improved PCE
performance was identified during the Unit 1 outage. No deficiencies
were identified with respect to adequacy of followup on individual
personnel contaminations. Licensee actions with respect to improving
personnel contamination controls were determined to be appropriate with
no regulatory concerns noted.
R1.4 External Occupational Exoosure Control and Personal Dosimetry
]
a.
Inspection Scope (83724)
i
The inspectors evaluated the adequacy of the licensee's program for
j
monitoring external occupational exposures during normal operations and
j
the adequacy of the licensee's personal dosimetry program. Emphasis was
'
given to the licensee's monitoring of occupational dose in buildings
close to but outside the restricted area fence that are within the
licensee's controlled area.
b.
Observations and Findinas
The inspectors reviewed area Thermoluminescent Dosimeter (TLD) results
for the period of January 11, 1996, through October 10, 1996, with focus
on exposures in buildings occupied by personnel adjacent to the
licensee's restricted area boundary fence. A review of these TLD
results averaged for a 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> work year indicated several work areas
outside the fence with elevated doses above the regulatory public dose
limit of 100 millirem 3er year. Doses for an average work year were
found to range from a ligh of 229 millirem on the second floor of the
Administrative Building to doses under 100 millirem in the TAC Building.
The elevated doses above the public dose limit were primarily
attributable to N 16 Turbine Shine resultant from the licensee's use of
Hydrogen Water Chemistry. The licensee's area TLD monitoring network
confirmed that doses to workers were the highest for those workers whose
offices were the closest to the source (Turbine Building) as might be
expected. Doses above the public dose limit were identified in the
Administrative Annex (Old Training) and Document Control Buildings
although these doses were less on average than those doses in the
Administrative Building. The inspectors review of licensee dosimetry,
monitoring, and general radiation control procedures indicated the
._.
.
_
. _ . . . _ . .
- - _ _ _ _ _ _
__
_
. .
_.
18
1
l
licensee did not treat dose to occupational workers in these buildings
in the controlled area as occupational dose and licensee procedures were
generally deficient in this regard. However, as defined in the
regulation, dose above the public dose limit which is received by a
l
worker in the course of employment during which the worker's assigned
~
,
l
duties involve exposure to radiation from licensed sources is
l
occupational dose. The licensee was aware that some workers outside of
I
the restricted area were receiving occupational doses above the public
dose limit incidental to their occupational activities based on limited
f
,
data contained in a dosimetry technical report (95 08) dated August 28,
1995. However, this report failed to address the issue comprehensively
other than to conclude that no workers exceeded the 500 millirem
monitoring threshold based on an analysis of actual individual summed
doses inside and outside the restricted area during mid 1995 and,
therefore, there was no regulatory requirement for the monitoring of
!
individuals in the controlled area.
The inspectors reviewed available dose data for radiation workers
outside the restricted area and determined that no workers were
exceeding regulato7 limits.
However, the inspectors reviewed dose
monitoring procedures as well as dose records of other categories of
individuals including members of the public, casual visitors, and the
exposure monitoring practices / procedures for declared pregnant women and
the embryo / fetus. No concerns were identified with respect to public or
casual visitors. However, because the regulatory limits for declared
pregnant women are at one tentn of occupational dose limits for exmsure
and monitoring the full population of declared pregnant women at t1e
site was reviewed for the prior two years. Of this population of
workers none were identified that exceeded regulatory limits with
respect to radiation exposure. A review of licensee actions with
respect to declared pregnant women indicated the licensee had taken
actions with respect to these workers post pregnancy declaration to
minimize occupational exposure.
Licensee actions included reassignment
of workers to less dose intensive duties to lower their exposures.
tiowever, the licensee was not monitoring declared pregnant women who
were working in the controlled area and had no procedural provision for
declared pregnant women who may work in buildings with exposure levels
above public dose limits. These workers, based on a review of area TLD
monitoring results for office space located in the controlled area, have
potential to receive during a nine month gestation period doses in
excess of the 50 millirem occupational dose limit at which monitoring is
required. Although no declared pregnant women were identified who would
actually exceed the 50 millirem monitoring limit based on specific
declaration dates and remaining periods of pregnancy, the workers
reviewed approached the limit (maximum prospective dose was 43 millirem)
indicating the need for monitoring as a conservative measure.
l
Incidental to this review the inspectors identified a defect with
respect to the applicable procedure for dosimetry issuance for the
,
monitoring of declared pregnant women. Carolina Power & Light Company
Nuclear Generation Grou) Standard Procedure DOS-NGGC 0002, " Dosimetry
Issuance", Revision 1
Effective Date August 12, 1996, states within
19
1
paragraph 9.9.5 Individual Monitoring of Declared Pregnant Women, "If
the woman works solely in the controlled area (does not enter the
restricted area), then individual monitoring is not required if the dose
is not likely to exceed 100 mrem in a year, the public dose limit."
This procedure directly contradicts the requirements of 10 CFR 20.1502
(a) (2) which requires licensees to monitor exposures to radiation for
declared pregnant women likely to receive in one year from sources
external to the body a dose in excess of 50 millirem. The failure to
implement a radiological control procedure consistent with the
requirements of 10 CFR 20.1502 (a) (2) is a violation of regulatory
requirements (VIO 50 325(324)/96 16 02), Failure to Implement a
Radiological Control Procedure Consistent with 10 CFR 20.1502 (a)(2).
'
The inspectors evaluated the licensee's procedures and practices with
<
respect to the monitoring and tracking of occupational dose for
radiation workers. The licensee was unable to demonstrate adecuately
during the period of inspection that occupational dose receivec by
workers in the controlled area was being considered in the prospective
analysis used to determine if workers required monitoring in accordance
with the requirements of 10 CFR 20.1502. Radiation workers who are
required to be monitored for radiation work in restricted areas, i.e.,
workers who are likely to receive greater than 500 millirem in a year
based on a prospective analysis of likely dose, are also required to be
'
monitored for occupational dose received in controlled areas. The
licensee was unable to produce records or reference procedures which
demonstrated full compliance with the requirements of 10 CFR 20.1502 for
monitoring occupational exposure. Additionally, the licensee was asked
to demonstrate, as conservative to radiological safety and within
regulatory requirements, the current dosimetry practice of subtracting
100% of turbine shine dose from the sitewide personnel TLDs stored in
racks at the entrances to the restricted area. The inspectors stated to
the licensee that this practice ap) eared nonconse'rvative with respect to
'
the accurate reporting of dose bot 1 in terms of cumulative site dose and
individual dose assignments. The licensee was unable to provide any
data to demonstrate this practice as conservative or reasonable during
the week of inspection. A subtraction of less than 100% of the turbine
shine dose would be a reasonable approach in the view of the inspectors
due to the fact that most of the TLDs actively in use are typically on
personnel inside the restricted area for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> or more during a
usual workyear. The subtraction from worker dose assignments of the
full turbine shine dose component as detected on the area TLDs in the
vicinity of the TLD racks (which includes the turbine shine dose workers
receive while working in the restricted area and while wearing their
TLDs) does not appear reasonable.
Subtracting the turbine shine dose
component incurred by radiation workers during normal working hours when
the TLDs are being worn by the radiation workers is not clearly
justifiable or conservative with respect to dose assignment practices.
The licensee indicated further evaluation and time to prepare a response
was necessary due in part to the need to coordinate a response with
corporate dosimetry personnel who worked offsite in the Harris Energy
and Environmental Center at New Hill, N. C.
These inspector concerns
20
were unresolved at the end of the inspection and will require further
evaluation of licensee data. These issues regarding demonstration of
accurate and reasonable dose tracking and dose assignment practices and
related procedures were identified to the licensee as Unresolved
Item (URI 50 325(324)/96 16-03), Unresolved Item for Lack of Accurate
Dose Tracking and Dose Assignment Practices and Related Procedures,
c.
Conclusions
The licensee's program for monitoring external exposure and tracking
dose within the restricted area was determined to be effective. The
licensee requires by procedure all radiation workers entering the
restricted area to be monitored by TLD and all workers entering the RCA
to be monitored with electronic dosimetry as well. The monitoring of
all workers inside the restricted area by TLDs for dose of record
pur)oses exceeds regulatory requirements in that only a fraction of the
wor (ers who actually enter the restricted area will exceed the 500
millirem threshold requiring monitoring.
Outside the restricted area,
however, licensee dosimetry procedures were deficient in that the
monitoring and tracking of occupational dose in the controlled area was
not adequately addressed in procedure.
Specifically, procedures which
require monitoring of dose in the controlled area for workers who are
required to be monitored in the restricted area and practices for
adjusting radiation worker dose assignments to eliminate all turbine
shine dose were identified to the licensee as issues requiring further
evaluation by the licensee and procedural treatment as appropriate.
These issues are an Unresolved Item with respect to dose tracking,
assignment of dose, and related procedural improvement. One violation
was identified for a dosimetry issuance procedure which allowed declared
pregnant women in the controlled area to go unmonitored for prospective
,
radiation dose above 50 millirem contrary to the requirements of 10 CFR 1502 (a) (2).
R5
Staff Training & Qualification in Radiation Protection and Chemistry
R5.1 Trainina of Radiation Workers
a.
Insoection Scope (83750)
The inspectors evaluated the adequacy of training of radiation workers
who were receiving occupational exposure consistent with the
requirements for training contained in 10 CFR 19.12. Also evaluated
were the qualifications of a recently assigned Radiation Protection
Manager to determine if all qualification requirements were satisfied
consistent with Technical Specification 6.3.1 and Reg Guide 1.8.
b.
Observations and Findinas
The inspectors determined that workers in the licensee's controlled area
i
and outside the restricted area were receiving occupational dose as
defined in 10 CFR Part 20 (also reference above Paragraph R.I.4.b.).
'
The intent of the training requirement of 10 CFR 19.12. Instruction to
21
Workers, is that individuals who are permitted to receive occupational
doses within occupational limits will receive appropriate training
commensurate with associated radiological risk.
Furthermore, when doses
received by workers are in fact occupational dose, appropriate
instructions should inform the worker that he/she is subject to
occupational dose limits rather than public dose limits.
Plant workers
have the right to be fully informed as to radiological hazards and
conditions of their workplace in order that they may make informed
decisions related to matters such as
minimizing of occupational exposure. pregnancy declaration and theThe inspe
a review of training material and related quizzes that the intent of 10 CFR 19.12 training was met by the licensee's Radiation Worker Training
course. The radiological training content of the licensee's Plant
Access Training was minimal, did not meet the intent of 10 CFR 19.12,
and was not sufficient to provide training commensurate with risk as
specified in regulatory guidance.
In order to ensure that workers who
were receiving occupational dose were trained in accordance with 10 CFR 19.12, the inspectors reviewed training records for a large sample of
workers whose normal work stations were in buildings in the controlled
area. Through this review it was determined that one or more workers
receiving occupational dose had not been trained in accordance with 10 CFR 19.12. These workers either currently were receiving or aotentially
could receive occupational dose that required the workers to
1 ave
radiation worker training. The failure of the licensee to have trained
all workers who were receiving occupational doses was determined to be a
violation of the requirements of 10 CFR 19.12. Although this violation
of regulatory requirements was NRC identified the violation will not be
cited due its isolated nature and relatively low safety significance.
The licensee committed to train the workers affected in accordance with
10 CFR 19.12 and committed to upgrade training for all workers in the
controlled area. This would ensure that they were aware of the
occupational doses being received to include a characterization of
associated radiological risks, and to conduct a review of rad worker
training adequacy in general to ensure that the full intent of 10 CFR 19.12 was being met for all workers receiving occupational exposures
both in restricted and controlled areas. The failure of the licensee to
train all workers in accordance with the requirements of 10 CFR 19.12.
Instruction to Workers, constitutes a violation of minor safety
significance and is being treated as a Non Cited Violation, consistent
with Section IV of the NRC Enforcement Policy (NCV 50-325(324)/96 16-
04), Failure to Train Workers Receiving Occupational Dose in Accordance
with 10 CFR 19.12.
A qualification review was conducted for a recently assigned Radiation
Protection Manager (RPM) to determine if the individual assigned
possessed the necessary qualifications for the position. Qualification
requirements, as committed to through the licensee's Technical Specification 6.3.1, specify that the RPM will meet or exceed the
1
cualifications outlined in Reg Guide 1.8. which include a bachelor's
cegree in science or engineering and five years experience in applied
radiation protection.
i
i
22
c.
Conclusions
Although the licensee was adequately training workers who work in the
restricted area in accordance with 10 CFR 19.12 Instruction to Workers,
the ins >ector identified a noncompliance with 10 CFR 19.12 in that not
all warcers who were receiving occupational dose were trained in
accordance with 10 CFR 19.12.
Specifically, examples of workers in the
controlled area were identified who were receiving occupational dose but
who were not trained in accordance with 10 CFR 19.12. This violation
will be treated as a Non Cited Violation consistent with Section IV of
A qualification review of an individual recently assigned as Radiation
Protection Manager concluded the individual was sufficiently qualified.
R8
Miscellaneous Radiation Protection and Chemistry Issues
R8.1 ALARA Proaram Effectiveness
a.
Insoection Scope (83750)
Part 20 to the Code of Federal Regulations requires that licensees use,
to the extent practicable, procedures and engineering controls based
upon sound radiation protection principles to achieve occupational doses
and doses to members of the public that are as low as reasonably
achievable. The ALARA area was evaluated to determine whether the
licensee was establishing and tracking performance against ALARA goals,
whether continuing ALARA initiatives are ongoing to reduce dose, and to
evaluate the overall effectiveness of the ALARA program.
b.
Observations and Findinas
Through November 6, 1996, the licensee projected a Unit 1 Refueling
Outage dose of 210.7 person rem and actually achieved a dose of 210.8
rem which was a) proximately equal to the goal. The outage dose goal was
revised upward )y ap3roximately 10 rem to allow for emergent work. The
licensee was on trac ( to achieve their annual dose goal of 688 rem based
on good dose performance during the Unit 1 refueling outage and low dose
accrual during power operation periods during 1996. The annual dose
goal, if achieved, is still at a relatively high level but represents
good dose performance for the site during a year with Unit 1 and Unit 2
refueling outages. The inspectors observed pre job ALARA briefings and
evaluated ALARA pre work packages for select high dose outage
activities. The inspectors noted thorough and detailed pre job planning
for specific high dose activities and observed good task analysis as
well as a cuestioning attitude as to potential dose saving opportunities
for plannec activities. The inspectors reviewed with the licensee
current and planned ALARA initiatives. During 1996, the licensee had
undertaken several dose reduction initiatives including expanded
application of shielding, additional advanced radiation worker training,
and additional emphasis on ALARA practices and dose ownership by all
organizational units. The licensee established an exposure goal for 1996
._.
__
-
. - -
-
- .
.
l
23
~
which, if achieved, will represent good dose performance at the site
during a year with two refueling outages. Notwithstanding this dose
performance, overall dose at the site remains relatively high. The
licensee did not undertake a full system chemical decon during B111R1
'
but did realize some dose reduction through hot spot flushing, zinc
injection in recirc piping, and a system hydrogen peroxide wash. The
licensee did not commit to a chemical decon based on a negative cost
benefit analysis using a site standard of $10,000 per rem and an
estimated saving of 55 rem for a full system decon during the B111R1
,
,
'
outage as well as additional rem savings during future outages. Despite
the decision not to undertake a full system chemical decon, the licensee
indicated an intent to evaluate the feasibility of conducting full
,
system chemical decons as an ALARA initiative during future outages.
l
.
Overall, the inspectors determined that collective dose is being
i
!
effectively controlled and reduced.
3
>
c.
Conclusions
j
'
I
.
Overall, based on an evaluation of ALARA initiatives and ALARA work
'
plans for high dose work evolutions, the inspectors concluded that the
licensee's ALARA program was adequately controlling collective dose and
that collective dose was on a favorable reducing trend. However, site
4
dose remains relatively high and continued ALARA initiatives to reduce
source term and reduce site dose are warranted.
1
i
F2
Status of Fire Protection Facilities and Equipment
F2.1 Fire Protection Desian Chance and Plant Modifications
a.
Inspection Scoce (71750. 64704)
.
The inspector reviewed the adequacy of a design change to a number of
plant automatic fire suppression systems associated with ESR 94 00345.
The inspector walked down the plant areas affected by the change to
4
.
inspect the implementation of the modification in the field and observed
'
portions of post modification testing.
i
i
b.
Observations and Findinas
The inspector reviewed implementation of ESR 94-00345. The purpose of
1
this modification was to decommission the Automatic Sprinkler
'
Corporation "Model C", primed-preaction deluge valves by removal of the
clapper, linkages, latching arm and sealing diaphragm, and sealing the
valve diaphragm opening with a cover plate. This type of valve had been
experiencing recurring failures including the inability to reset the
latching arm and re)eated rupturing of the latch arm diaphragm seal.
Failure of the diapiragm seal resulted in continuous water leakage to
the floor area near the valve assembly. This modification effectively
2
eliminated the preaction valve function and converted the preaction
system to a full flow wet pipe sprinkler system design.
. , . .
-
-
. .-
. .
.
. -
. .
.
.
.-
-
_- -
4
24
The modification involved changes to the following fire suppression
system deluge valves:
Reactor Buildinas
1
1-FP DV20,
2 FP DV20,
1 FP-DV319,
2 FP DV319
'
j
Diesel Generator Buildina
l
2 FP-DV13,
2 FP DV16,
2-FP DV19
Service Water Intake Buildina
2 FP DV21,
Radwaste Buildina
"
2-FP DV704
i
The licensee's engineers reviewed the internal flooding analysis and
calculations for the Reactor Buildings, Diesel Generator Building,
Radwaste Building, and Service Water Building and concluded that due to
the physical separation of redundant safety related equipment in the
Reactor Buildings and documented conclusions of previous flooding
analysis, the modification did not alter these analysis nor the
redundancy of the systems. The inspector reviewed the history and
assum)tions for the modification and the 10 CFR 50.59 Safety Evaluation
for t1e changes and determined that they were adequately evaluated.
No
unreviewed safety concerns were found, however, the inspector identified
a UFSAR discrepancy associated with flooding protection in the reactor
!.
buildings.
,
UFSAR Section 3.4.2.1 states that Class I Motor Control Centers and
instrument racks in the reactor buildings, when near (water) leakage
sources, were provided with drip shields to minimize damage.
During the
walkdown of areas of the reactor buildings where automatic sprinkler
protection is provided the inspector identified that Class I instrument
'
racks H21-P009 on the 20' elevation and H21-P014, P017, P018, and P022
on the -17' elevation were not provided with drip shields.
In some
cases sprinklers heads and piping were installed within five feet above
these instrument racks. Additional licensee walkdowns of other reactor
building elevations indicated that dri> shields had not been installed
over any of the Class I instrument rac(s within areas provided with
automatic wet pipe sprinkler systems in the RBs.
After discussions witt, the licensee, Condition Report CR 96-03943 was
issued to track the failure to provide dri) shields over Class I
instrument racks near leakage sources in t1e reactor buildings. This
-
. - _ .
_ _ -
_ _.
- . .
.
. - .
.
-
.
.-
.
'
i
1
25
UFSAR discrepancy was identified by the inspector, and is discussed in
3
Section F2.2.
A review of post modification testing for modification ESR 94 00345 was
performed to confirm that appropriate National Fire Protection
Association hydrostatic test pressures and duration had been specified.
On November 25, 1996, the inspector observed the successful hydrostatic
'
testing for a deluge system protecting the diesel generator building.
No discrepancies were identified.
2
i
c.
Conclusions
,
'
The inspectors concluded that the design change and plant modifications
of the deluge valves were adequate, however, the design review failed to
'
identify an UFSAR discrepancy associated with internal flooding in the
i
reactor building.
F2.2 Special UFSAR Review
'
A recent discovery of a licensee o>erating the facility in a manner
contrary to the UFSAR description lighlighted the need for a special
'
focused review that compares plant practices, procedures, and/or
parameters to the UFSAR descriptions. While performing the inspections
discussed in this resort, the inspectors reviewed the applicable
portions of the UFSA1 that related to the areas inspected. The
inspectors verified that the UFSAR wording was consistent with the
observed plant practices, procedures, and/or parameters.
l
The licensee started a review of the UFSAR on July 1,1996. After the
first quarter of review, the licensee had written 23 condition reports
for 70 discrepancies. This number of problems indicated a programmatic
'
problem with maintaining the UFSAR current.
.
The inspector reviewed UFSAR Section 3.4.2.1, as part of the fire
-
protection ESR modification walkdown activities. An inconsistency was
noted in that the licensee failed to provide drip shields over Class I
instrument racks near leakage sources in the reactor buildings. This
issue is discussed in Section F2.1. This item will be identified as
'
"
part of URI 325(324)/96 05 02.
!
.
1
4
i
i
_
_
. _ _ _
. . _ - ~ _ _ .
. . _ .
_ _ _ . -
_ _ _ _ _. _ ___
_ .- _ .
. . _
!
l
i
26
V.
Manaoement Meetinas
XI
Exit Meetina Summary
The inspector presented the inspection results to members of licensee
I
management at the conclusion of the inspection on December 12, 1996. On
December 19, 1996, the licensee was informed that 3revious unresolved
item 325/96 15 02. Loss of Shutdown Cooling, was clanged to violation
325/96 16 01 discussed in this re> ort. Post ins)ection briefings were
'
conducted on November 7 and Decem>er 6, 1996. T1e licensee acknowledged
I
the findings presented.
l
The licensee did not identify any materials used during the inspection
as proprietary information.
.
i
27
PARTIAL LIST OF PERSONS CONTACTED
Licensee
G. Barnes, Manager Training
C. Barnhill, Dosimetry Supervisor, E&RC
A. Brittain, Manager Security
W. Campbell, Vice President, Brunswick Steam Electric Plant
R. Crate, Radwaste Upgrade Project Manager
B. Deacy, Outage Manager
N. Gannon, Manager Maintenance
J. Gawron, Manager Nuclear Assessment
W. Icenogle, Corporate Dosimetry, Harris Energy & Environmental Center
W. Levis, Director Site Operations
R. Lopriore, General Plant Manager
J. Lyash, Brunswick Engineering Support Section
J. McGowan, Senior Specialist, Regulatory Affairs
B. Nurnburger, Superintendent, Environmental and Chemistry
C. Pardee, Manager Operations
P. Sawyer, Acting Superintendent, Radiation Protection
R. Schlichter, Manager Environmental and Radiation Control
S. Tabor, Senior Specialist, Regulatory Affairs
J. Terry, Program Analyst, E&RC
M. Turkal, Supervisor Licensing and Regul6 tory Programs
H. Wall. Training Supervisor
Other licensee employees or contractors included office, operation,
maintenance, chemistry, radiation, and corporate personnel.
E. Brown
M. Janus
C. Patterson
W. Rankin
G. Wiseman
._
-.
_____
-_
._
__._m
. _ . _ _ _ . _ _ . -
4
t
28
INSPECTION PROCEDURES USED
'.
IP 37551:
Onsite Engineering
IP 40500:
Effectiveness of Licensee Controls in Identifying, Resolving, and
Preventing Problems
,
IP 61726:
Surveillance Observations
IP 62707:
Maintenance Observations
IP 71707:
Plant Operations
IP 71714:
Cold Weather Preparations
IP 71750:
Plant Support Activities
'
IP 83724:
External Occu3ational Exposure Control and Personal Dosimetry
IP 83729:
Occupational
ladiation Exposure During Outage
-
IP 83750:
Occupational Radiation Exposure During Power
.i
IP 92901:
Followup - Operations
i
'
ITEMS OPENED, CLOSED, AND DISCUSSED
1
Doened
4
50 325(324)/96 16 01
Improper Work Planning Resulted in a Loss of
Shutdown Cooling (Paragraph 02.1)
,
50-325(324)/96 16 02
Failure to Implement a Radiological Control
a
Procedure Consistent with 10 CFR 20.1502 (a)(2)
i
(Paragraph R1.4)
50 325(324)/96 16 03
Unresolved Item for Lack of Accurate Dose
i
Tracking and Dose Assignment Practices and
Related Procedures
(Paragraph R1.4)
50 325(324)/96 16 04
Failure to Train Workers Receiving Occupational
Dose in Accordance with 10 CFR 19.12 (Paragraph
R5.1)
Closed
50 325/96 15 02
Loss of Shutdown Cooling (Paragraph 08.1)
Discussed
50 325(324)/96-05 02
UFSAR Discrepancies (Paragraph F2.2)