ML20210H345

Insp Repts 50-324/86-07 & 50-325/86-06 on 860210-14. Violation Noted:Failure to Adequately Access Airborne Contamination

ML20210H345
Person / Time
Site:	Brunswick
Issue date:	03/11/1986
From:	Collins T, Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210H331	List: ML20210H326 ML20210H334 ML20210H345
References
50-324-86-07, 50-324-86-7, 50-325-86-06, 50-325-86-6, NUDOCS 8604030042
Download: ML20210H345 (9)

See also: IR 05000324/1986007

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n 8 Rec uNITIO STATES

4 oq'o, NUCLEAR REGULATORY COMMISSION

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Report Nos.: 50-325/86-06 and 50-324/86-07

Licensee: Carolina Power and Light Company

P. O. Box 1551

Raleigh, NC 27602

Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62

Facility Name: Brunswick 1 ..nd 2

Inspection Co ucted: Feorua 1 14, 1986

Inspectors: //

W. T. Coope

ed.J. . MN8S

Date Signed

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T. R. CollYns

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Date Signed

Accompanying Personnel:, C. M. Hosey

Approved by: ) ,

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C. M. Hosef, Sectf on Chief Date Signed

Divisten of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 88 inspector-hours on site

in the areas of evaluation of the licensee's program to maintain exposures as low

as reasonably achievable (ALARA), internal and external exposure controls,

qualifications of contract health physics staff, and transfer and storage of

radioactive material.

Results: One violation - failure to adequately assess airborne contamination.

0604030042 860321

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. REPORT DETAILS

1. Persons Contacted

Licensee Employees

• P. Howe, Vice President-Brunswick Nuclear Plant

• J. Chase, Assistant to General Manager .

• E. Bishop, Manager-Operations

• J. Smith, Director-Administrative Support -

• B. Hinkley, Manager-Technical Support

• J. O'Sullivan, Manager-Maintenance

• R. Mayton, Manager-Corporate Health Physics

• A. Cheatham, Manager-Environmental and Radiological Controls

• L. Tripp, Su;>ervisor-RC-1

• J. Kiser, Project Specialist-RC

• L. Jones, Director-Quality Assurance / Quality Control

• K. Enzor, Director-Regulatory Compliance

.* R. Poulk, Senior Specialist-NRC ,

• J. Holder, Outage Management

• T. Wyllie, Manager-Engineering and Construction

• R. Groover, project Construction Manager

• J. Brown, Resident Engineer

• P. Foscolo, Construction Supervisor

• J. Gdido, Senior Health Physics Specialist

D. LaBelle, Shift Operations Supervisor

S. Carr, Radwaste Operations Shift Supervisor

R. Warden, Instrument and Control Unit 1 Supervisor

S. Smith, Senior Specialist I&C-

J. Henderson, Supervisor-Radiation Control-2

J. Terry, Project Specialist-ALARA

C. Barnhill, Radiation Control Foreman

T. Priest, Radiation Control Foreman

Other licensee employees contacted included 3 construction craf tsmen, 5

technicians, 2 operators, and 4 office persennel.

NRC Resident Inspectors

• W. Ruland, Senior Resident Inspector

L. Garner, Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on February 14, 1986, vith

those persons indicated in Paragraph I above. The inspector discussed the

itcensee ALARA program in detail with licensee management (Paragraph 10).

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The inspector also discussed an apparent violation of 10 CFR 20.103 for

failure to adequately sample airborne contamination (paragraph 9) and an

unresolved item * concerning the transfer of radioactive materials through

the unrestricted area to the Low Level Waste Storage Facility

(paragraph 11). A licensee representative stated that exception may be

taken with the apparent violation for failure tc adequately sample airborne

contamination. The licensee did not identify as proprietary any of the

materials provided to or reviewed by the inspectors during this inspection.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. Trainir.g and Qur.lifications (83723)

a. Contract Technician Training and Qualifications i

The inspector reviewed the program for qualification of contract  ;

radiation protection technicians. The inspector discussed separately -

with one contract technician his previous experience and training to

determine if it was comprehensive or if it had been limited to selected- r

tasks. The inspector also discusse0 the training and qualificattori

orogram the licensee had provided, what limits had been placed on their i

activities, and controls that should be established for several tasks f

they were qualified to perform. The inspector reviewed the resumes,  ;

training records, and tests for selected technicians. I

No violations or deviations were identified. ,

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5. Organization and Management Controls (83722) ,

a. Organization [

The licensee was required by Technical Specification (TS) 6.2.2 to i

implement the plant organization specified in Figure 6.2.2-1. The  !

responsibilities, authorities, and other management controls were

further outlined in Chapters 12 and 11 of the FSAR. TS 6.5.3.3  ;

specified the members of the Plant Nuclear Safety Committee (PNSC) and t

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"An Unresolved Item is a matter about which more information is required to e

determine whether it is acceptable or may involve a violation or deviation.

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outlined its functions and authorities. Regulatory Guide 8.8 specified

certain functicas and responsibilities to be assigned to the Radiation

Protection Manager and radiation protection responsibilities to be

assigned to line management.

The inspector reviewed recent changes to the plant organization to

determine their effect on plant radiological controls, by examining the

resulting changes to administrative procedures and position descrip-

tions. These changes were discussed with the Radiation Protection

Manager and the Radiation Control Supervisor.

The inspector discussed with an operations shif t foreman, radiation

protection foreman, chemistry foreman, and shift foreman, the type,

methods of, and degree of interaction between plant groups. The

inspector discussed with the Radiation C>rotection Manager and Radiation

Control Supervisors, how frequently they toured the plant and radiation

control areas.

b. Staffing

Technical Specification 6.2.2 specified minimum plant staffing. FSAR

Chapters 12 and 13 outlined further details on staffing. The inspector

discussed authorized staffing levels versus actual on-board staffing

with the Radiation Control Supervisor. The inspector examined shift

staffing for the d&yshift on February 12, 1986, to determine if it met

minimum criteria for radiation protection.

No violations or deviations were identified.

6. Control of Radioactive Materials and Contamination, Surveys, and Monitoring

(83726)

The licensee was required by 10 CFR 20.201(b) 20.403, and 20.401 to perform

surveys to show compliance with regulatory limits and to maintain records of

such surveys. Chapter 12 of the FSAR outlined survey methods and

instrumentation. TS 6.8 required the licensee to follow written procedures.

Radiological control procedures further outlined survey methods and

frequencies.

a. Surveys

The inspector observed, during plant tours, surveys being perforwed by

radiation protection staff and reviewed several Radiation Work Permits

(RWPs), to determine if adequate controls were specified. The

inspector discussed the controls and monitoring with the radiation

protection technicians assigned.

During plant tours, the inspector observed radiation level and

contamination survey results outside selected cubicles. The inspector

performed independent radiation level surveys af selected areas and

compared them to licensee survey results. The inspector reviewed

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selected survey records for the month of February 1986 and discussed

with licensee representatives methods. used to disseminate survey

results. The inspector noted that there were several locked high

radiation areas outside containment.

b. Frisking

During tours of the plant, the inspector observed the exit of workers

and movement of material from contamination control to clean areas to

determine if proper frisking was performed by workers and if proper

direct and removable contamination surveys were performed on materials.

c. Instrumentation

During plant tours, the inspector observed the use of survey instru-

ments by plant staff and compared plar.t survey meter results with

results of surveys made by the inspector using NRC equipment. The

inspector examined calibration stickers on radiation protection

instruments in use by licensee staf f and stored in the radiation

protection laboratory,

d. Release of Materials for Unrestricted Use

The inspector discussed, with a radiation protection technician, the

program for survey-out of items from contaminated areas and reviewed

the procedures for such release. The inspector observed release

surveys performed by radiation protection technicians and documer.tation

c f results. The inspector performed confirmatory direct contamination

surveys on several items released. During tours of plant areas, the

inspector observed labeling of containers and performed independent

surveys to determine if containers of radioactive material were

properly icentified.

No violations or deviations were identified.

7. Facilities and Equipment (83727)

FSAR Chapters 1 and 12 specified plant layout and radiation protection

facilities and equipment. During plant tours, the inspector observed the

flow of traffic through change rooms, the use of temporary shielding, glove

bags, and ventilated containment enclosures.

No violations or deviations were identified.

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8. External Occupational Dose Control and Personal Dosimetry (83724)

During plant tours, the inspector checked the security of the locks at

several locked high radiation areas, observed posting of survey results and'

reviewed the controls specified on several RWPs.

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a. Use of Dosimeters and Controls

The licensee was required by 10 CFR 20.202, 20.201(b), 20.101, 20.102,

, . . 20.104, 20.402, 20.403, 20.405,19.13, 20.407, and 20.408 to maintain

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worker's doses. below specified levels and to keep records of and make

reports of doses. The licensee was required by 10 CFR 20.203 and

TS 6.12 to post ar.J control access to plant areas. FSAR Chapter 12

l also contained commitments regarding dosimetry and dose controls.

l During observation of work in the plant., the inspector observed the

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wearing of thermoluminescent-dosimeters (TLDs) and pocket dosimeters by

i workers. The inspector discussed the assignment and use of dosimeters

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with selected radiation protection technicians. During plant tours,

r the inspector observed the posting of areas and made independent

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measurements of dose to assure proper posting. The inspectnr reviawed

i recent changes to plant procedures regarding the use of TLDs and

dosimeters.

l_ b ', Dosimetry Results

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The inspector reviewed the TLD results for 1985 and for the first

quarter of 1986. These results showed that two individuals had

received greater than four rems in 1985. For several individuals who

received greater than 1.25 rems in one quarter, the inspector examined

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each individual's dosimetry file to determine if Form NRC-4 had been

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c. Management Review of Dosimetry Results

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l The inspector discussed the dosimetry results with an operations

( supervisor to determine his understanding of radiological controls for

l his staff. The inspector reviewed . records of administrative dose

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control extensions for the year of 1985 and discussed the extensions

with selected supervisors and staff. The inspector reviewed records of

cases where workers exceeded ' administrative controls without dose

extensions,

l No violations or deviations were identified.

9. Internal Exposure Control and Assessment (83725)

The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403, and

20.a05 to control uptakes of radioactive material, assess such uptakes, and

keep records of and make reports of such uptakes. FSAR Chapter 12 also

included commitments regarding internal exposure control and assessment.

a. Control Measures

l During plant tours, the inspector observed the use of temporary

l ventilation systems, containment enclosures, and respirators. The

! inspector discussed the use of this equipment with radiation protection

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technicians and reviewed recent changes to respiratory protection

procedures.

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b. Uptake Assessment

The inspector observed operation of the whole body counter and

discussed its operation and results with the counter operator. The

inspector reviewed the results of the analyses performed for two

maintenance mechanics who had positive counts during 1985. The

inspector discussed the resulting assessments and corrective actions-

with the Radiation Control Supervisor. The maximum count observed was

a 44 percent ( *.) Maximum Permissible Organ Burden (MP08). The

inspector reviewed the event which led to the uptake of the apparent

44* MP0B. The licensee was in the process of installing equipment in

the reactor cavity during a refueling outage. The individual in

question, entered the reactor cavity on December 8, 1985 to ' provide

support for equipment installation. Previous survey results performed

by the licensee revealed that removable contamination levels in the

area were less than 100,000 disintegrations per minute (dpm) per 100

square centimeters (cmr ) and that airborne radioactivity levels were

less than the licensee action limit for respiratory protection. During

the time the individual was working in the reactor cavity, he was told

to clean up some paint chips w the vicinity of the fuel canal. Upon

exiting the reactor cavity, the individual performed a whole body frisk

and found his face and nostrils contaminated. Subsequent surveys

performed by the Health Physics Staff substantiated that the individual

had received an intake of radioactive material. ' Whole body count

results revealed a 44*. MP0B which calculated to approximately 35

maximum permissable concentration (MPC)-hours. The inspector concluded

from his review that the area where the individual had been working had

contamination levels as high as 400,000 dpm/100 cm* and that the

licensee did not take representative breathing zone air samples to

adequately evaluate the radiation hazards present to workers. The air

rample taken, which was not representative for the work performed, was

not evaluated until approximately two hours af ter the event. Failure

to adequately monitor the airborne radioactivity levels in the work

area was identified as an apparent violation of 10 CFR 20.103(a)(3)

(50-324/86-07-01 and 50-325/86-06-01).

10. Maintaining Occupational Exposures ALARA (83528)

10 CFR 20.1(c) specified that licensees should implement programs to keep

worker's exposures ALARA. FSAR Chapter 12 also contained licensee

commitments regarding worker ALARA actions,

a. Worker and Supervisor Actions

The inspector interviewed selected members of the plant staf f to

determine their understanding of ALARA and ALARA concepts. The

inspector discussed with supervisory personnel the methods used to

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disseminate information concerning ALARA good practices, goals and

objectives to their employees.

b. ALARA Reviews

The inspector discussed with the ALARA Coordinator the review of

proposed plant modifications by the ALARA group. The ALARA Coordinator

stated that approximately 100 modification packages had been reviewed

by his staff during the month between the Unit 1 and Unit 2 outages.

The number of reviews required to be completed within the one month

time frame appeared to be more work than the assigned staff could

complete and be able to give each package the necessary attention.

Plant management stated that the licensee had requested that the NRC's

Office of Nuclear Reactor Regulation (NRR) allow the facility to

operate until the end of core life in March 1986, so that planning and

preparartion for the outage could be completed. The Brunswick facility

had requested an exemption from the regulations in order to operate

with non-environmentally qualified equipment. This exemption was

denied by the Commissioners on October 4, 1985. The licensee chose to

begin the Unit 2 outage at the time of shutdown, even though some

outage planning had been assumed a later shutdown time and even though

some ALARA reviews were not complete.

c. ALARA Program Evaluation

During interviews with workers, the inspector found that ALARA aware-

ness was increasing when compared to the previous inspection. Plant

management was dedicated to reducing the exposures of plant personnel

and that dedication was reaching to the worker level. The licensee was

implementing a program for exposure accountability whereby a supervisor

would have ALARA incorporated as a critical element into his annual

performance evaluation. The critical element would require that each

foreman, supervisor and manager be responsible for maintaining

exposures ALARA.

The inspector discussed the following additional ALARA program items

with licensee representatives. At the conclusion of the discussion,

licensee management stated that these items would be evaluated:

1) As stated above, more than 100 modification work packages had to

be reviewed in four weeks by two licensee personnel, causing an

apparent inattention to detail due to the amount of work requiring

review by the group.

2) The Brunswick Construction Unit (BCU) ALARA Coordinator operated

his section in compliance with plant procedures but acted

independently of the plant ALARA program. No specific point of

contact in the plant organization was designated for BCU ALARA,

3) Senior members of the plant staff were not members of the ALARA

Subcommittee. Licensee management stated that the PNSC reviews

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! The inspector noted increased awareness of ALARA and its goals and

l' objectives during this inspection. Licensee personnel interviewed

during this inspection exhibited an adequate knowledge of exposure ,

reduction methods and techniques. The licensee had relocated check- t

points, dress-out and staging areas from the reactor building to the  ;

breezeway. The licensee estimated that the move would save an L

estimated 15 to 45 man-rem during the present outage. Chemical

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decontamination of the recirculation piping . prior to performing weld -

overlays was estimated to save the licensee approximately 1000 man-rem

during the outage.

Licensee management appeared to be taking a considerably more

aggressive posture in attempts to reduce the cumulative exposures for

the plant, and as a result, the ALARA program appears to be improving.

11. Solid Wastes (84722)

On February 11, 1986, the inspectors observed the movement of thirteen

80-25 boxes containing low level radioactive waste between the

licensee's protected area and the Low Level Waste Storage Facility.

Movement of this material required that the boxes be loaded onto a  !

flatbed wagon for transport, exit the licensee's protected Area, and

move through a parking lot enroute to the Storage Facility, a distance 4

of approximately one-fourth mile. The transit route was entirely on

owner-controlled property. The inspectors reviewed the survey data

associated with this transfer, which indicated dose rates on contact

with the boxes of 1 millirem per hour to 135 millirem per hour. A

licensee representative stated that such transfers were under the

control of an ANSI qualified health physics technician and that

calculations performed prior to such transfers indicated that exposures .

to personnel outside the protected area would be less than regulatory

limits. The inspector stated that the boxes being transferred were not >

placarded in accordance with 49 CFR 172, no shipping papers accompanied  ;

the transfer in accordance with 10 CFR 71.5 and the box lids were not r

secured in accordance with 10 CFR 71.43. Alsr, radiation levels on the

exterior surfaces of the packages indicatsi's %at an individual, if .

continuously present in the area, could re.eive a dose in excess of two

millirems in any one hour. This item vas identified as unresolved l

pending review by the Regional office staff. The Regional staff I

reviewed the unresolved item detailed above. The staff determined that i

with the radiation level limits the licensee had in place, a person

present during tha transfer of material could not recieve a dose in 'i

excess of regulatory limits, therefore, this item is closed. ,

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