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Insp Repts 50-324/88-09 & 50-325/88-09 on 880208-12. Violations Noted.Major Areas Inspected:Audits & Appraisals, Outage Planning & Preparation,Training & Qualification of New Personnel & Internal & External Exposure Programs
	ML20148D842
Person / Time
Site:	Brunswick
Issue date:	03/10/1988
From:	Bassett C, Hosey C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20148D819	List: ML20148D814; ML20148D834; ML20148D842;
References
	50-324-88-09, 50-324-88-9, 50-325-88-09, 50-325-88-9, NUDOCS 8803240349
	Download: ML20148D842 (11)
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UNITED STATES

NUCLEAR REGULATORY COMMISSION

o * REGION il

i< [ 101 MARIETTA ST., N.W.

,,,,, ATLANTA, GEORGIA 30323

MAR 161988

Report Nos.: 50-325/88-09,50-324/88-09

Licensee: Carolina Power and Light Company

P. O. Box 1551

Raleigh, NC 27602

Docket Nos.: 50-325, 50-324 License Nos.: OPR-71, OPR-62

Facility Name: Brunswick

Inspection Conducted: February 8-12, 1988

Inspector: la

. H. Bbssett v Date Signed

Accompanying Personnel: C. M. Hosey

R. B. Shortridge

Approvedby:.L bdw

p.M.iHosey,SectionChief

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Date' Signed

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Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection was conducted in the areas of

audits and appraisals, outage planning and preparation; training and

qualification of new personnel; external exposure control; internal e'posure

control; control of radioactive material, contamination, surveys and

monitoring; maintaining exposures as low as reasonably achievabir.: (ALARA);and

information notices followup.

Results: Two violations were identified - (1) failure to maintain access to a

high radiation area locked (see Paragraph 4.d.(2)); and (2) failure to fcilow

procedures or to have adequate procedures (see Paragraphs 4.d.(3), 4.h.(1),

4.h.(2)).

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REPORT DETAILS

1. ~ Persons Contacted

Licensee Employees

C. Barnhill, Dosimetry Foreman, Environmental and Radiological Control

E. Bishop, Manager, Operations

C. Blackman, Superintendent, Operations

S. Callis, Onsite Licensing Engineer

A. Cheatham, Manager, Environmental and Radiological Control

E. Eckstein, Manager, Technical Support

K. Enzor, Director, Regulatory Compliance

R. Helme, Director, Onsite Nuclear Safety

J. Henderson, Supervisor, Environmental and Radiclogical Control

P. Howe, Vice President, Brunswick Nuclear Project

L. Jones, Director, Quality Assurance / Quality Control

J. O'Sullivan, Manager, Maintenance

R. Queener, Physical Engineer, Environmental and Radiological Control

J. Smith, Director, Administrative Support

J. Terry, ALARA Coordinator, Environmental and Radiological Control

L. Tripp, Supervisor, Environmental and Radiological Control

Other licensee employees contacted included construction craftsmen,

, engineers, technicians, operators, mechanics, security office members, and

i office personnel. ;

NRC Resident inspector

W. Ruland

Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on February 12, 1988,

with those persons indicated in Paragraph 1 above. The inspector

described the areas inspected and discussed in detail the inspection

findings listed below. The licensee acknowledged the inspection findings.

However, licensee management stated that they might deny the violation for

an inadequate procedure regarding reading of relf reading pocket

dosimeters since the event was still under investigation. The licensee

also stated that they considered that appropriate corrective actions had

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been taken regarding the auxiliary operator displaying poor radiological

work practices. The licensee did not identify as proprietary any of the

material provided to or reviewed by the inspector during this inspection. 1

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3. Licensee Action on Previous Enforcement Matters

(Closed) Unresolved Item (325/87-39-03, 324/87-40-03), Poor radiological

work practices exhibited by an auxiliary operator. See Paragraphs 4.d.2

and 3 of report details.

4. Occupational Exposure During Extended Outages (83728)

a. Audits and Appraisals (83722, 83724, 83725, 83726, 83728)

The inspector reviewed audits of the radiation protection program

performed in 1986 and 1987. The extent of audits, qualifications of

auditors, and adequacy of the audits were assessed. During the

review the inspector noted that of the ten monthly assessments

performed by the corporate radiological protection group and reviewed

by the inspector, none identified any radiological deficiencies or

necessary corrective actions designed to improve the stations'

radiation protection program. In late 1987 the corporate group

, performing the audits / assessments function was disbanded and the

auditors reassigned to other departments as a result of a corporate

reorganization. The licensee stated that a new audit program was

being developed and would be implemented as soon as possible. Audits

or assessments performed by the new audit program will be reviewed

during the next inspection.

No violations or deviations were identified,

b. Planning and Preparation (83724, 83725)

Tne trasent health physics organization, staffing levels, and lines

of authority as related to outage radiation protection activities

were discussed with licensee representatives. The organizational

responsibility and control of the contractor HP technicians used

during the outage was also discussed. The licensee's HP organization

consisted of a radiation protection manager, two supervisors, eight

foremen, nine technical support personnel and sixty technicians. To

provide additional job coverage required by the Unit 2 outage, the

licensee increased the staff with eighty-three contract HP

technicians. After training had been completed and verified,

contractor HP technicians were integrated into the non-supervisory

! positions, commensurate with the experience and qualifications.

Licensee personnel maintained supervision over the HP contract

technicians to assure compliance with established procedures and an

acceptable quality of work was attained. Staffing levels for the

outage appeared to be adequate.

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No violations or deviations were identified.

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c. Training and Qualificahon (83723)

(1) Technical Specification 6.3 required that each member of the HP

staff meet or exceed the minimum qualifications of ANSI

N18.1-1971. Paragraph 4.5.2 of ANSI N18.1 stated that

technicians in responsible positions were to have a minimum of

two years of working experience in their speciality. The

licensee in practice requires that an individual have three

years experie0ce to perfor.n the tasks assigned to junior

technicians, teree to five years experience to perform as a

technician and five or more years to be a senior technician.

The inspector reviewed records of selected health physics

technicians and noted that their qualifications and experience

level appeared to be commensurate with their job assignments and

responsibilities.

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(2) Contractor Health Physics Technician Training and Qualification

The 83 HP technicians contracted to augment the licensee's HP

staff received 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months of classroom training in site

radiological plant specifics in the areas of proceduras,

instruments, basic health physics, problem solving and safety.

To successfully complete the HP orientation, a contract

individual must score 80 percent on an exanination to be

classified a junior technician and eight-five percent to be

classified as a senior technician. Prior to assignments of job

coverage, the contractor technicians must satisfactorily

demonstrate their knowledge and skills by performing the same

tasks required of licensee technicians. The checkout of a

contractor technician, in selected tasks, is monitored by a

licensee-qualified instructor. Upon successful completion of

the task, the instructor signs off the contractor technician's

job perfornance on the same qualification-card required of

licensee HP technicians. After completion of on the job

iraining and qualification, the contractor technician is

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assigned radiological job coverage responsibilities.

No violations or deviations were identified,

d. External Exposure Control and Dosimetry (83724)

(1) Use of Dosimeters

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10 CFR 20.202 requires eaC1 licensee to supply appropriate

personnel monitoring devices to specific individuals and require

the use of such equipment. During tours of Units 1 and 2

reactor building, the inspector observed the use of

thennoluninescent dosimeters (TLDs) and self-reading pocket

dosimeters (SRPDs). It was noted that workers typically placed

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their SRPDs inside their protective clothing. The inspector

discussed with the licensee the potential for workers to

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contaminate themselves if they reach inside their protective

clothing to read their SRPD to monitor their exposure. The

licensee stated they would review this matter and that'

appropriate corrective actions would be taken.

(2) Radiologically Controlled Areas

Technical Specification 6.12.2 requires that each high radiation

area, in which the intensity is greater than 1,000 mrem /hr, have

locked doors to prevent unauthorized entry.

The inspector- reviewed an unresolved item as reported in

Inspection Report 87-39 and 87-40 dated December 29, 1987. The

unresolved item concerned an event which occurred on November

12, 1987, during which a NRC resident inspector accompanied an

Auxiliary Operator (A0) making daily rounds of Unit 2 Reactor -

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Building. The A0 was observed to unlock a chainlink door to

access the Unit 2, 80 foot east fuel pool heat exchanger room, a

high radiation area. The A0 left the area for a period of about

5 minutes to dress out in protective clothing. During this

period the high radiation area was unlocked and unattended,

however, the inspector stood by the door and stated that no

unauthorized entry was made by anyone into the area. A review

of radiation surveys of the area taken on November 14, 1987,

showed maximum general area radiation levels of 60-700 mrem /hr

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with a.5,000 mrem /hr hot spot. No radiation readings were taken

to determine the radiation levels in the accessible areas

immediate adjacent to the hot spot. The inspector and licensee

toured the area on February 11, 1988, and noted that the area

adjacent to the hot spot could be accessed by an individual.

The licensee controlled access to the fuel pool heat exchanger

room as a high radiation area and required the door to the area

to be locked. Failure to maintain access to a high radiation

area locked was identified as an apparent violation of 1

10CFR20.203(c)(iii)(50-325,324/88-09-01).

(3) Radiation Work Permits (RWPs)

i Technical Specification 6.8.1 requires that written procedures

I be established, implemented, and maintained covering the

activities recomended in Appendix A, of Regulatory Guide 1.33

of November 1972.

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Regulatory Guide 1.3?. Quality Assurance Program Requirements,

I Appendix A. Section . A recomends that the licensee have

l procedures for perfonw.,9 maintenance and Section G.5 recomends .

procedures for personnel radiation monitoring and special work

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permits.Section I.S.b recomends that factors be taken into

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account in preparing detailed work procedures, including the

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necessity for minimizing radiation exposure to workmen.

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Technical Specification 6.11.1 requires that procedures for

personnel radiation protection shall be prepared consistent with

the requirements of 10 CFR Part 20 and shall be approved,

maintained, and adhered to for all operations.

Radiation Control and Protection Procedure, Volume Vill,

Section 6.6.3 states that required items of protective clothing

shall be worn by all personnel while in radiation controlled

areas.

On November 12, 1987, while the NPC resident inspector

accompanied the A0 making daily rounds of the plant, the

inspector observed the A0 violate protective clothing

requirements on two occasions. The A0 entered the 80 foot Fuel

Pool Heat Exchanger area and the mini-steam tunnel with a hard

hat instead of a hood as required by RWP-1002, Revision 0,

locally posted dress out requirements, and prior instructions

from the duty health physics technician.

Failure of the A0 to comply with RWP requirements in that he

failed to wear the correct protective clcthing was identified as

an apparent violation of Technical Specification 6.8.1 (325,

324/88-09-02).

The inspector reviewed general and special RWPs posted at the

entrance to the radiologically controlled area to verify they

complied with regulatory requirements and contained sufficient

guidance,

e. Internal Exposure Control (83725)

(1) Intake Assessment

10 CFR 20.103(a) establishes the limits for exposure of

individuals to concentrations of radioactive materials in air in

restricted areas. This section also requires that suitable

measurements of concentrations of radioactive materials in air

be performed to detect and evaluate the airborne radioactivity

in restricted areas and that appropriate bioassays be performed

to detect and assess intakes of radioactivity.

The inspector reviewed selected results of general inplant air

samples taken during the refueling outage and results of air

samples taken to support work authorized by special radiation

work permits. The inspector also reviewed the selected results

of whole body counts.

(2) Engineeririg Controls and Respirctory Protection

10 CFR 20.103(b)(1) requires that the licensee use process or

other engineering controls to the extent practicable to limit

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concentrations of radioactive materials in the air to levels

below those which delineate an airborne radioactivity area as

defined in 20.203(d)(1)(ii).

During plant tours, the inspector'cbserved various engineering

controls to limit the concentrations of airborne radioactive

material. These included the use of temporary ventilation

systems, containment enclosures, and air supplied respirators.

The inspector discussed the use of respiratory equipment with

the licensee to ensure that medical evaluations and fit testing

were performed prior to respirator use. Selected records were

reviewed to ensure that the required training and medical

evaluations were documented.

No violations or deviations were identified,

f. Control of Radioactive Materials and Contamination, Surveys and

Monitoring (83726)

(1) Surveys

The licensee was required by 10 CFR 20.201(b) and 20.401 to

perform surveys and to maintain records of such surveys

necessary to show compliance with regulatory limits.

During plant tours, the inspector examined radiation levels and

contamination survey results posted outside various areas

including Units 1 and 2 drywells. The inspector performed

independent surveys of selected areas using NRC equipment and

compared them with licensee survey results. The inspector also

examined licensee radiation protection instrumentation and

verified that the calibration stickers were current. .

(2) Caution Signs, Labels and Controls

10 CFR 20,203(f) requires that each container of licensed

radioactive material bear a durable, clearly visible label

identifying the contents when quantities of radioactive material

exceeded those specified in Appendix C.

During plant tours the inspector verified that containers of

radioactive material were properly labeled when required.

(3) Area and Personnel Contamination

The inspector reviewed records of skin contamination occurrence

for 1987 and the current outage. The licensee had 420 skin

and/or clothing contaminations in 1987 and 77 through the first

5 weeks in 1988.

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The licensee maintains approximately 625,000 square feet of the

Unit 1 and Unit 2 reactor buildings and turbine building as a

radiologically controlled area. Approximately 66,373 square

feet or 9.4 percent is controlled as contaminated areas.

No violations or deviations were identified.

9 Program for Maintaining Exposures As Low As Reasonably Achievable

(ALARA) (83728)

10 CFR 20.1(c) states that persons engaged in activities under

licenses issued by the NRC should make every reasonable effort to

maintain radiation exposure ALARA. The recommended elements of an

ALARA procram were contained in Regulatory Guides 8.8, Information

Relevant to Ensuring that Occupational Radiation Exposure at Nuclear

Power Stations will be ALARA, and 8.10, Operating Philosophy for

Maintaining Occupational Radiation Exposures ALARA.

ALARA Program

The inspector discussed the ALARA Program with licensee

representatives. During calendar year 1987 the collective exposure

man-rem goal with 1 refueling outage was 1,209 man-rem and

1,419 man-rem was expended. The 1988 man-rem goal is 1,530 with two

scheduled outages. The first refueling outage goal is 852 man-rem.

On February 12, 1988, the licensee had expended 476 of 479 projected

man-rem for the first outage. The annual collective exposure goal

was established at the station and was based on specific jobs and

outage workscope. The inspector reviewed the planning for the

refueling outage in progress and the outage report for the previous

refueling outage in 1987. The job history / lessons learned section of

the report contained substantive ALARA considerations to be used in

minimizing radiation exposure for subsequent, similar or repeat

operations. The planning document for the current outage did not '

appear to address, in the same level of detail, the ALARA

considerations from the previous outage report. Consideration of

lessons learned in outage planning will be reviewed during subsequent

inspection.

No violations or deviations were identified.

h. Radiological Events Review

(1) On January 3,1988, the licensee was transferring a startup

range monitor dry tube via over head crane to a storage location

in the spent fuel pool (SFP). Due to the length of the dry

tubes and configuration of the path from the reactor vessel

cavity to the spent fuel pool, the crane is required to be

positioned at the far section of the SFP away from the reactor

cavii.y(to

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normally lowered as far into the SFP as possible. The lower end

of the dry tube is then raised, a bow in the tube rotating

downward occurs, and the lower end of the dry tube is moved out

of the cattle chute area and lowered to the SFP for storage.

Normally the dry tube is maintained underwater to provide

shielding during the operation for_ these highly irradiated

components. During this event the crane hoist was correctly

located.but a problem with the hydraulic cables on the gripper

tool prevented lowering the dry tube to the correct location

necessary to raise and rotate the other. end of the dry tube.

With the upper end of the dry tube at a higher position than

normal, the bottom of the dry tube was raised using a "J" hook

tool. The dry tube bowed in an upward direction causing a

highly irradiated section of the tube to break the water. When

this occurred the area radiation monitor alarmed and the

technician handling the J hook was instructed to drop the tube

back into the water. The dry tube was out of the water for a

maximum of 2 to 3 seconds. Radiation surveys on a similar dry

tube read approximately 4,000 rem /hr on contact. The highest

exposure to an individual involved in the event was 30 mrem.

The inspector discussed the operation with the cognizant

engineer and reviewed the SRM Dry Tube Removal Procedure,

ENP-46. The procedure did not contain the necessary information

and precautionary steps to prevent the dry tube removal from

exposing personnel to high levels of radiation. The upper end

of the dry. tube was in too high a position to ensure a downward

rotation when the lower end was raised. The procedure step used

to rotate the dry tube was broad in nature and allowed several

actions to be performed simultaneously instead of several steps

that are used in sequence. Failure of the procedure to include

the necessary factors for minimizing radiation exposure to

workmen was identified as an additional example of an apparent

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violation of Technical Specification 6.8.1 (50-325,

324/88-09-02).

(2) On January 23, 1988, a licensee individual entered the Unit 2

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drywell to prepare a weld on the feedwater nozzle for inservice

l inspection. General arer, dose rates in the work area ranged

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from 30 to 150 mrem /hr with contact readings on a shielded valve

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penetration located in the work area from 300 to 1,200 mrem /hr.

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Radiation Work Permit 88-1053 Attachment A, in part, required

l that continuous coverage be provided by health physics during

I the operation, that work should be planned to reduce stay-time

l and generation of radwaste, and that work area dose rates be

monitored often. After approximately 15 minutes in the drywell,

the worker read his SRPD as suggested by Radiation Control and

Protection Procedure, Volume VIII and noted 40 mrem. He began

to prepare the weld surface by flapping with a grinder. After

completing the weld prep which took approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the

worker read his SRPD for a second time and noted that it was

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offscale. The worker exited the drywell and reported to health

physics. Processing of the workers TLD revealed that he

received an exposure of 1,120 mrem for the quarter and 800 mrem

during the entry on January 23. This exceeded the licensee's

administrative limit of 1,000 mrem per quarter. An

investigation by health physics of the event revealed that the

same operation had previously been performed several times in

the area resulting consistently in exposures of 20 to 50 mrems.

Health physics personnel responsible for drywell coverage did

not observe the worker during the weld prep operation as

required by the RWP. Although the worker was aware of

1,000 mrem /hr dose rates, he failed to read his SRPD.

The inspector asked HP supervision and technicians what their

understanding of continuous coverage meant. There were several

interpretations that ranged from control point entry at the

drywell constituted continuous coverage, to intermittent

coverage (10 to 15 minute checks), to constant coverage during

the entire job. In March 1986 HP management issued a memorandum

to define continuous coverage but this allowed a HP technician

the option of uninterrupted positive control (constant) or

periodic surveillance intermittent consistent with the

radiological hazard. The licensee stated that corrective action

of strictly defining continuous HP technician coverage would be

taken.

Based on a review of radiological procedures and the radiation

work permit requirements the inspector determined that the

werker was not required by procedures or RWP to frequently read

his SRPD while in radiation or high radiation areas. Radiation

Control and Protection Procedure, Volume VIII, Section 6.6.2 is

considered inadequate in that it failed to require that SRPD be

read frequently when an individual is in a high radiation area

to minimize exposure. Failure to have an adequate procedure was

identified as an additional example of an apparent violation of

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Technical Specification 6.8.1(50-325,324/88-09-02).

l i . Radiological Controls for Drywell During Spent Fuel Movement

l (Tl 2500/23)

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l During a previous inspection, controls used during spent fuel

movement were reviewed and appeared to be adequate. At that time the

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licensee indicated that a new portable fuel-chute shield or "cattle

l chute" was being fabricated and the various dimensions and amounts of

I shielding were discussed. The inspector questioned the adequacy of

! the shielding and the licensee indicated that further consideration

would be given to the design and fabrication of the new chute.

During this inspection, the inspector reviewed the specifications of

l the new cattle chute and the radiological analyses of several

! postulated fuel drop accidents performed after some design changes

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and shielding modifications were made. The newly fabricated cattle

chute now appears to be adequate, with six inches of lead shielding

in the floor of the chute. If a fuel bundle were inadvertently :

dropped in the chute, the highest calculated dose rate at one foot

from the chute in the drywell would be 4.3 rem per hour. At 40 feet

from the chute inside the drywell, or the area allowed to be occupied i

during fuel transfer by procedure, the calculated dose rate would be

35 millirem per hour.

No violations or deviations were identified.

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j. Information Notices (92717)

The inspector determined that the following NRC Information Notices ,

had been received by the licensee, reviewed for applicability, *

distributed to the appropriate personnel and that actions, as

appropriate, were taken or scheduled:

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IN 87-28, Air System Problems at U.S. Light Water Reactors

IN 87-31, Blocking, Bracing, and Securing of Radioactive

Materials Packages in Transportation !

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4 IN 87-39, Control of Hot Particle Contamination at Nuclear Power i

Plants !

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ML20148D842

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