ML20198N656
| ML20198N656 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/30/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20198N643 | List: |
| References | |
| 50-324-97-14, 50-325-97-14, NUDOCS 9801210160 | |
| Download: ML20198N656 (7) | |
See also: IR 05000324/1997014
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S. NUCLEAR REGULATORY COMMISSION
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REGION 11
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Docket Nos:
50-325, 50-324
License Nos:
Report No:
50-325/97-14, 50 324/97-14
Licensee:
Carolina Power & Light (CP&L)
Facility:
Brunswick Steam Electric Plant. Units 1 & 2
Location:
8470 River Road SE
Southport. NC 28461
Dates:
December 9-12, 1997
Inspector:
W. Rankin. Senior Project Manager
Approved by:
K. Barr, Chief. Plant Support Branch
Division of Reactor Safety
9901210160 971230
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ADOCK 05000324
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Enclosure 2
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EXECUTIVE SUMMARY
Brunswick Steam Electric Plant Units 1 & 2
NRC Inspection Report Nos. 50J> /97-14 '50-324/97-14
Plant Sunoort
The radiation control program uas effectively implemented with good
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occupational exposure controls c5 served during norndl plant operations,
(Section R1.1)
The licensee's_off-site dose projection software. CPLDOSE, was evaluated
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and determined to be functioning as designed with no flaws identified.
(Section R8.1)
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Ona violation was identified for failure to control a Locked High
Radiation Area in accordance with procedure. (Section RI.1)
' e
One violation was identified for failure to initiate a condition report
- upon identifying a Locked High Radiation Area not co.ntrolled in
accordance with procedure. (Section R1.1)
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Report Details
Plant Support
R1
Radiation Protection and Chemistry Controls
R1.2 Extern;
Occooational Exoosure Conttch
a.
Insoection Scooe (83750)
The inspector evaluated aspects of the licensee's radiation control
program against the applicable requirements of 10 CFR Part 20. Technical
Specifications, and the Updated Final Safety Analysis Report (UFSAR).
The inspector also evaluated licensee radiological controls with
emphasis on on external occupational exposure during normal plant
operations.
b.
Observations and Findinas
The inspector made tours of the radiation control area, observed
compliance of licensee personnel with radiation protection procedures
for routine work evolutions, and conducted interviews with licensee
personnel with respect to knowledge of radiation controls and specific
radiological working conditions.
During plant walkdowns within the Radiologically Controlled Area IPCA),
the inspector conducted brief interviews at random with radiattor,
workers inside the RCA in order to determine the level of understanding
of Radiation Work Permit (RWP) requirements and radiation working
conditions. The workers interviewed were verified to have signed on to
an RWP. were wearing dosimetry appropriate to their work activities
within the RCA, and were performing specific work activities on
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appropriate RWPs.
The inspector reviewed total effective doses for radiation workers at
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the site and determined that all personnel exposures assigned since the
beginning of 1997 through December 11, 1997 were within 10 CFR Part 20
limits.
The inspector determined that the licensee had adequately
monitored and tracked individual occupation ' radiation exposures in
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accordance with 10 CFR Part 20 requirements and that doses reported were
at a small percentage of regulatory limits.
The inspector reviewed and discussed with licensee representatives the
program for satrolling access to high radiation areas (HRAs), locked .
high radiation areas (LHRAs). and very high radiation areas (VHRAs).
These areas were inspected during tours of Unit 1 and Unit 2 for proper
posting and access controls.
No HRAs. LHRAs. or VHRAs were identified
where required posting was needed but not posted. Areas controlled as-
a LHRAs-were inspected and found locked in accordance with licensee
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procedure. Key controls for entry into locked and very high radiation
areas were evaluated against the requirements of the licensee's-
administrative control procedure and determined to be controlled in
accordance with procedure.
During evaluation of LHRA controls the inspector reviewed the licensee's
use of a 200 Curie Cs-137 source used primarily in the calibration of
pocket dosimeters maintained for emergency preparedness purposes. Upon
review of radiological surveys conducted during recent uses of the
Cs-137 source, it was determined that on November 18. 1997, the area met
Technical Specification 6.12.2 LHRA criteria and OE&RC-0040 " Control of
Locked High Radiation and Very High Radiation Areas". Rev. 15. Step 7.1.
procedural requirements for an area that must be controlled as a LHRA in
that area dose rates exceeded 1 Rem /hr.
The applicable survey for the
calibration room (Survey No. 1118-30 dated 11/18/97) performed during
the calibration work with the Cs-137 source exposed (at the three foot
elevation with shields out) indicated 10 Rem /Hr. near the ceiling and
1.5-2.0 Rem /Hr. behind the shield window which constituted general area
readings in the room of greater than 1 Rem /Hr. These general area
radiation levels in the room at the time met LHRA criteriu and
necessitated LHRA controls for the period during which these conditions
existed. However. during interviews with radiation control personnel
directly involved with the specific controls that were in place at the
start of the dosimeter calibration work on November 18. 1997, the
inspector determined that the calibration room was not controlled in
accordance with LHRA procedural requirements.
Specifically, access was
not properly controlled and the entrance to the room was not secured
with designated special cal-core locks required for LHRAs prior to to
leaving the area unguarded. Although the actual doses received by the
radiction workers involved with the dosimetry calibration work conducted
on November 18. 1997 were small. the radiological controls in place were
not sufficient to provide reasonable assurance against the potential for
greater exposure. Of particular concern were the insufficient controls
for the foot pedal and the " source up" control panel which were not
locked out or controlled in any positive manner.
Although the door to
the calibration room containing the source was maintained locked,
insufficient positive control over the door key inventory was evident.
The licensee was informed the failure to control tne calibration room as
a LHRA was a violation of licensee procedure OE&RC-0040 requirements.
This is designated Violation 50-325(324)/97-14-01. Failure to control a
Locked High Radiation Area in accordance with procedural requirements.
During discussions with licensee radiation control personnel associated
with the November 18. 1997 dosimetry calibration work. the inspector
inquired as to the status of corrective actions for the adverse
conditions identified. Licensee representatives indicated that
immediate corrective actions were undertaken at the time of the incident
to include dedicated job coverage by a qualified Radiation Control
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Technician through completion of the dosimeter calibration work. The
inspector determined, however, that no follow up_ corrective actions had
occurred and in fact, the incident was ncver documented in Condition
Reports despite the relative significance of a failure to control a LHRA
in accordance with TS and procedural requirements.
10 CFR 50. Appendix
B. Criterion XVI, requires that measures shall be established to assure
that conditions adverse to quality, such as deficiencies and
nonconformances, are promptly identified and corrected. CP&L Procedure
PLP-04. " Corrective Act'on Management". Revision 23. dated 10/27/97.
1mplements the requirements of Criterion 16 at the Brunswick Nuclear
Plant. Attachment 6 of PLP-04. " Criteria for Condition Reports", states
under examples of conditions which should be Condition Reports, a person
who does not mmply with procedure requirements such as passes material
across a contamination barrier or who does not frisk when required.
Paragraph 6.0 of PLP-04 requires that personnel shall review their
activities for adverse conditions which meet the threshold for
initiating a Condition Report and, upon identifying such a condition,
personnel must initiate a Condition Report. Contrary to this procedural
requirement. on November 18. 1997, the licensee failed to initiate a
Condition Report upon identifying a LHRA not properly controlled in
accordance with procedures, an adverse condition which met the threshold
for initiating a Condition Report. The licensee was informed this
failure to initiate a Condition Report in accordance with procedure was
a violation and is designated Violation 50-325(324)/97-14-02. Failure to
initiate a Condition Report for a LHRA not properly controlled.
c.
Conclusions
The radiological controls program was effectively implemented with good
occupational exposure controls demonstrated overall during routine plant
operations. However, one violation was identified for failure to
control a Locked High Radiation Area in accordance with procedural
requirements. Another violation was identified for failure to initiate
a Condition Report for the LHRA not properly controlled.
R8
Miscellaneous Radiation Protection & Chemistry Issues
R8.1 Offsite Dose Projection Under Acci P t Conditions
a.
Insoection Scoce (827011
The inspector evaluated the licensee's capabilities to provide off-site
radiological dose projections during accident conditions consistent with
the requirements of the licensee's emergency plan and plant emergency
procedure OPEP-03.4.7. "Offsite Dose Projection". Rev.10. Emphasis was
given to capabilities of the licensee's dose projection software.
CPLDOSE. to provide dose projections for spent fuel handling accidents.
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Observati.g s and Findinas
b.
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The inspector evaluated the dose projection capabilities of CPLDOSE
under accident conditions involving a dropped fuel bundle and related
fuel handling accident scenarios.
Specifically examined was the design
basis refueling accident in which one fuel assembly is assumed to fall
on to the top of an uncovered reactor core as analyzed in Section 15.7.1
of the UFSAR. A review of CPLDOSE and projected outputs verified that
the CPLDOSE dose projection methodoloay made valid dose projections for
this bounding " worst case" fuel handling accident condition under a
range of source terms, durations, and atmospheric dispersion factors.
The inspector also reviewed a condition report (CR-02632 dated 7/31/97)
which stated that the CPLDOSE source term was potentially invalid for
fuel handling accidents because reactor shutdown time was believed to
affect source term calculations for fuel handling accidents.
The CR
stated that data input for the variable time since reautor shutdown
should have little correlation to a fuel handling accident dose
projection.
The inspector reviewed with the licensee's senior HP
analyst with technical cognizance for the CPLDOSE methodology the
licensee's evaluation for closure of the condition report. This
evaluation contained analysis for old spent fuel (>5 yrs.) and current
spent fuel and projected the off-site dose consequence for a series of
reactor shutdown times. In each case the source term changed with time
as expected and the dose projection model was validated for the input
data.
The inspector reviawed the evaluation and determined the analysis
to be valid with reasonable assumptions used.
No errors were identified
in the dose projection methodology during this review.
During the
period of time that CPLDOSE was under a five evaluation for the
potential error above (7/31/97 until 8/13/97), the inspector was able to
verify with operations personnel that no fuel movements had occurred.
c. Conclusions
The licensee's offsite dose projection software. CPLDOSE was evaluated
and determined to be functioning as designed with no flaws identified.
V.
Manaaement Meetinas
XI.
Exit Meetina Summary
The inspector presented the inspection results to members of licensee
management at the conclusion of the inspection on December 12, 1997. The
licensee acknowledged the findings presented.
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PARTIAL LIST OF PERSONS CONTACTED
L1sAufER
M. Christinziano. Manager. Environmental and Radiation Control
R. Crate. Superintendent. Radiation Protection
S. Hinnant. Vice. President. Brunswick Steam Electric Plant
W. Hinson, Radiation _ Control Supervisor-Dosimetry
K. Jury. Manager, Regulatory Affairs
J. Lyash. Plant General Manager
D. Pacini. Radiation Control Supervisor
T. Priest. Radiation Control Supervisor
P. Sawyer. Radiation Control Supervisor
S. Tabor. Senior Specialist. Regulatory Compliance
Other licensee employees or contractors included office, operations,
chemistry, and radiation control personnel.
IEC
E. Brown Resident Inspector
E. Guthrie. Resident Inspector
-C. Patterson. Senior Resident Inspector
INSPECTION PROCEDURES USED
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IP 83750: Occupational Radiation Exposure Controls
ITEMS OPENED. CLOSED, AND DISCUSSED
Onened-
50-325(324)/97-14-01
Failure to control a Locked High Radiation Area
in accordance with procedure (Section R1.1)
50-325(324)/97-14-02
Failure to initiate a condition report upon
identifying a Locked High Radiation Area not
controlled in accordance with procedure
(Section Rl.1)
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