IR 05000324/1990043

Insp Repts 50-325/90-43 & 50-324/90-43 on 901015-19. Violation Noted.Major Areas Inspected:Occupational Exposure During Extended Outages,Alara Activities,Access Controls for Entry Into High Radiation Areas & 900705 Event

ML20058K278
Person / Time
Site:	Brunswick
Issue date:	11/14/1990
From:	Potter J, Shortridge R, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058K275	List: IR 05000324/1990043 ML20058K272
References
50-324-90-43, 50-325-90-43, NUDOCS 9012170102
Download: ML20058K278 (8)

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A UNITED STATES i

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NUCLEAR REGULATORY COMMisslON y'" n REGION 11 g ij 101 MARIETTA STREET, * e ATLANTA, GEORGI A 30323 j s*****/ DEC 0 31990 i Report Nos.: 50-325/90-43 and 50-324/90-43 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 facility Name: Brunswick 1 and 2 Inspection Conducted: October 15 - 19, 1990 Inspectors:T.~)C'Y:.7'

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Ta////f/6 te Signed

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d- d Approved by:,J_. (P,o.tter,t __ef

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.ba[te/igned gfo Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY ,

Scope: This announced inspection of radiation protection' activities included a review of: ' occupational exposure during extended outages as low as reasonably .

achievable (ALARA) activities, access controis for' entry into high radiation areas, personnel extremity dose assignment associated with

the licensee's Traversing Incote Probe.(TIP) event of July 5, 1990, and the' conditions of the licensee's clean-up phase separator tank roo Results: One violation was identified for failure to take adequate corrective l actions' to prevent recurring _ Technical Specification (TS) violations of access control requirements for high radiation areas. The NRC was still evaluating the extremity dose assignment for a . unplanned TIP exposure.' and - the safety significance of the clean-up phase separator tank room's contaminated conditions.'

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REPORT DETAILS Persons Contacted Licensee Employees

• S. Callis, On-Site Representative, Licensing

• A. Cheatham, Manager, Environmental and Radiation Control (E&RC)

• Dorman, Manager, Quality Assurance and Quality Controi

• H. Foss, Supervisor, Regulatory Compliance  !

• J. Harness, General Manager l

• K. Harris, Senior Specialist, Regulatory Compliance  !

• R. Helme, Manager Technical Support .

• J. Holder, Manager, Outage Management and Modifications

• M. Jones, Manager..On-Site Nuclear Safety

• J. Moyer, Technical Assistant to Plant General Manager i

• P. Musser, Manager, Maintenance Staff j

• G. Peeler, Manager of Planning and Scheduling, Outage Management and i Modifications i R. Smith, Manager, Radiation Controls, E&RC P. Sneed, ALARA Supervisor, E&RC .

J. Terry, Radiation Control Project Specialist i

• K. Williamson, Manansr, Nuclear Engineering Department  ;

Other licensee emp1 gees contacted during .this 1.'spection included technicians, engineers and office personnel.-

Nuclear Regulatory Comission

• J. Potter, Section-Chief. Facilities Radiation Protection Staff Region II

• D Prevatte, Sei.ior Resident Inspector

• Attended exit intery bw held October 19, 1990~ Occupation Exposu e During Extended Outages (83729)

The inspectors rinviewed selected Radiation Work Permits (RKPs) for appropriateness cf the radiation protection requirements based on work {

scope, location, and conditions. During tours of the plant, the inspectors '

observed the adherence of plant workers to the RWP requirements and discussed the RWP requirements .with plant workers at the job site. The reviewed RWPs appeared to be adequate for the described radiological hazards and working condition i 10 CFR 20.203 specifies the posting, labeling,'and . control requirements '

! for radiation areas, high radiation areas, airborne radioactivity areas, t l and radioactive material. Additional requirements for control of high l radiation areas were contained in TS 6'12. During tours of the plant, the

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inspectors reviewed the licensee's posting and. control of radiation areas,-

high radiation areas, airborne radioactivity areas, contamination areas,

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radioactive material areas, and the labeling of radioactive material. All areas appeared to be properly posted and controlled. Paragraph 6 of this i report describes access control problems identified by the licensee prior to this inspectio CFR 20 202 requires each-licensee to supply appropriate personnel monitoring equipment to specific individuals and require the use of such *

equipment. During tours of the plant, the inspectors observed workers wearing appropriate personnel monitoring device CFR 19.12 requires the licensee to instruct all individuals working in or frequenting any portion of the restricted area, in the ~ health protection problems associated with the exposure to radioactive material or radiation; in the precautions to minimize' exposures; and in- the purposes and functions of' protective devices employed, applicable provisions of Comission Regulations, individual responsibilities, and in the availability of radiation exposure dat The inspectors reviewed the licensee's program for selection, training, and assignment of contract health physics (HP) technicians. Eighty vendor HP technicians had been contracted to supplement the sites HP staff during the scheduled 160 day Unit I refueling and-recirculation pipe replacement outage. Environmental and Radiological Controls (ESRC) - 60 Training and Qualification of Contract Personnel, Revision 20, dated August 21, 1990, specified the training and qualification requirements for HP contractor technician training. The inspectors reviewed contract HP technician

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training records and noted that those personnel received training on site specific previouslyradiological requirements, worked at Brunswick), radiation and Real - Timetheory (if they Training . (RTT)had not

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consisted of discussions between the training specialist and contract HP personnel regarding specific methods of job coverage and E&RC policie The training specialist also determines specific knowledge and skills during these discussions. Based 'on a ruiew of all contiact HP technician

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training records and job assignments,' the inspectors determined that all HP contractor- technicians were appropriately assigned and were qualified as _ required by E8RC-60. The inspectors noted that HP contractor technicians were not included in continuing training, but were given information on industry events (radiological.- problems occurring in the

industry). The inspectors noted that supervisory reviews of HP contrector

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training records were not being performed in a timely manner. The licensee-I stated that the subject reviews would be performe The inspectors also reviewed the lesson plans and attended an ALARA orientation for contract personnel participating in the recircult, tion pipe

replacement project. Lesson plan objectives were clearly defined and the l training included instruction in all elements, administrative and technical, of the recirculation pipe replacement project. Instruction focused on the methods to reduce personnel dose and good work practices, ,

as well as, the overall outage work scope and schedul No violations or deviations were identified.

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3. ALARA

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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 exposuret a low as reasonably achievable. The recommended elements of cr. ALARA program are contained in Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiaticn Exposures ALAR The inspectors reviewed selected ALARA activities for the Unit I refueling

, and pipe replacement outage. Procedure BSP-35, Pre-Outage Planning, Revision 0, dated October 27, 1989, delineated the functions, responsibilities, and required milestones to ensure that adequate resources were allocated for the outage. The procedures also focused on the effective communication requirements between - numerous work group BSP-35 required outage work scopes to be frozer for all outages 16 months prior to the scheduled start date. The inspectors noted that this was a positive step in addressing a previously identified NRC initiative that collective dose was high at the utility, particularly due to failure to adequately control outage work scope. The licensee was actively addressing other NRC identified initiatives regarding dose reduction. A program to identify unnecessary dose acquired in performing rework had been implemented and the number of personnel designated to support outage work had been reduced approximately 20 percent. Management 'and ALARA staff personnel implemented a new administrative control for ecliective dose monitoring. The system was~ designed % notify the staff of. jobs nearing .

their estimated dose and to allow the application of additional dose reduction measures as appropriat i Although the Unit I refuel and recirculation pipe replacement outage work I

scope was larger than Unit 2's, an aggressive ALARA collective dose goal of 376 person-rem had been established for the outage. The ALARA staff believed that the lessons learned during the previous pipe replacement outage would make the goal achievable. Two weeks into the Unit 1 outage I the licensee had exper.ded 93.4 person-rem, that was one percent-over the

! projected dose for that period in the outage. The inspectors determined

that 635.4 person rem had been expended in 1990.. to date. That was 45 percent of the site dose goal of 1,400 person-re Contract incentives were also established for outage ALARA objectives.

CP&L and major vendors for the pipe replacement portion of the outage l agreed upon ALARA dose goals that included financial incentives and penalties for the ' contractors success or failure in meeting dose goal objectives. . The contract incentives and accountability for keeping personnel radiation exposures low had been utilized in the Unit 2 recirculation pipe outage and had been determined to be a successful means

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of lowering contractor collective dos r

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Chemical decontamination of the primary reactor recirculation system was performed prior to beginning outage work activities. The inspectors noted that a savings of 160 person-rem for Unit 2 recirculation system decontamination, and 47 person-rem for Unit 2 nozzle flushes had been postulated as save Following a review of licensee procedures, the inspectors toured the mock-up training area for recirculation pipe cutting and welding support personnel and noted that improvements in the training and qualification of those personnel had been mad The inspectors determined, based on observation and program review, that

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the licensee was actively implementing ALARA dose reduction principles and techniques at the Brunswick facilit No violations or deviations were identifie . Review of the Radiological Conditions of the Reactor Water Clean-Up (RWCU)

Clean-Up Phase Separator Tank (CUPST) Room (Unresolved Item 50-325, 324/90-34-44)

Resident NRC inspectors referred a review of the radiological conditions of the facilities RWCU CUPST room to Region II's Facilities Radiation Protection staff. This item was identified as unresolved in Inspection Report No. 50-325/90-3 The CUPST room.was located on the -3 foot elevation of

! the radioactive waste building. Inspectors determined that the room l' contained an average of 2 inches of dried powder and bead resin on the

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floor that had been spilled and accumulated on the' floor from tank over flows several years ago. The tank room did not have < any equipment requiring access on a regular basis and access to the room was infrequent and opened about once per year. The general area dose rates in the room

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from the last radiation survey made January 17,_1990, showed the radiation dose rates were between 2 to 10 rem per hour (rem /hr) fror' the tanks and 2 to 5 rem /hr from the resin 'he floor. The inspectors determined that staff engineers had performed a safety evaluation of the rooms condition and found that the condition of the RWCU CUPST room did not constitute an unreviewed safety question. The licensee's evaluation of the room's '

condition is still under review by the NR No v.olations or di . ions were identified.

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i 5. Review of Extremity . Josure Estimates for July 5, TIP Event l On-July 5,1990, instrumentation- technicians were installing a new gama TIP for the Unit 2 Reactor. The technicians inserted the new detector into I the reactor's core and accidentally withdrew the' detector- and cable into their work area at the D TIF Drive Box. The event- was reviewed -by Radiation Specialist from Region 11 staff during the week of July 9-13, 1990, and documented in Inspection Report (IR) 50-324, 325/90-25 issued July 25, 1990. At that time, the licensee had not provided the estimated dose calculation bases and assumptions to the Region 11 staff. Several e questions concerning- the . licen;ee's calculatics were developed when the data was provided to the inspectors. Duri* 'he inspection, the

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licensee's calculations and methods were ' reviewed with the licensee's corporate and site personnel responsible for determining the workers extremity dose. Following that review, additional concerns regarding the licensee's dose. calculations were identified and continue to be reviewe No additional violations or deviations were identifie ,

6. Access Controls for High Radiation Areas with Dose Rates Greater than i 1,000 Millirem Per Hour (mrem /hr)

10. CFR 50, Appendix B, Criterion XVI states that measures shall be established to assure that conditions adverse- to quality, such as deviations, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetitio CFR 20.203(c)(2)(iii) requires that each entrance or access point to a high radiation area be maintained locked except during periods when access to the area is required, with positive control over each individua' entr TS 6.12.2 requires that each high radiation area, in which the .adiation intensity is greater than 1,000 mrem /hr, have lockec doors N prevent unauthorized entr NRC 1R 50-324, 325/90-06, dated March 8,1990, documentd five se aarate events in which the licensee or a NRC inspector had found high raciation area doors unlocked or unattended with no positive control over each entry. The licensee responded to the violation in a reply ddted April 6 '

1990, and stated in part, that the events were due to a combination of personnel errors and mechanicci problems with high radiation area door locking mechanisms. In addition to counseling HP and Operations personnel, site management initiated a centralized locked high radiation area door key control and accountability program, and implemented a preventative maintenance programEvaluation a Human Performance for the subj(ect door HPE) would beThe response performed also for the reported that previous TS 6.12.2 violations and when completed, would provide a supplemental response detailing any additional corrective actions that would be neede The supplemental response was to be submitted to the NRC by June 29, 199 On June 29, 1990, the licensee notified the NRC that the supplemental response would be provided by August 17, 1990, detailing the results of the. HPE along ~ with a proposed schedule for implementation of the recommended change ,

On August 3,1990, a sixth event occurred when a high radiation area door that was required to be controlled in accordance with TS 6.1 requirements was found unsecured by the HP staff during a routine chec ,

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On August 16, 1990, the. licensee provided a supplemental response to the violation. In addition to the previously identified corrective actions, the supplemental response reported that a HPE had identified design deficiencies with latched gates and that the Nuclear Engineering

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Depa r t'nent was requested to determine most feasible methods for eliminating the design deficiencies involved with the latched gates. The response reptpted that the work requested on the gates was considered an j enhancement to the 9rograntnatic changes that already had been made. The 1 licensee response scated that the real issue with the' door control was not with poor door design, but rather with the failure of individuals to verify that high radiation area doors were closed and latched when unattende j The supplemental response reported that the corrective action was completed. The licensee stated that based on the effectiveness of the programs established since the issuance of the violation in both the prevention of these deficiencies and the effectiveness and timeliness of discovery of the deficiencies, CP&L considered the BSP program for the control of high radiation area doors to:be in compliance with the TS requirement '

NRC inspectors conducting a routine radiological protection inspection during the week of August 20-24, 1990, reviewed the licensee's completed f corrective action for the Auaust 3,1990, violation and notified licensee I management that since the -licensee's corrective action for the 90-06 violation had not been completed when the sixth event occurred, on ,

August 3, 1990, additional enforcement measures would not be pursued and the violation would be closed. However, the licensee was notified at the exit meeting and later in'NRC Inspection Report 50-324,325/90-34, issued Octcher 5, 1990, that any further violations of the-TS requirements for securing access to high radiation areas could be cause for additional enforcement actions.

l On September' 20, 1990, licnesee HP personnel discovered another violation of the TS requiren.ents for the control of high radiation areas when the northeast turbine access door on the 70 foot elevation of Unit 2 was found unlocked during a routine high radiation door check. The item was L

identified by the. Resident NRC Inspectors in their September 19901R r 50-324, 325/90-37, as an Unresolved item (URI) (50-324/90-37 01). This was the se/enth example of failure to secure high radiation areas in accordance with the requirements described in TS 6.12.2. Further ,

investigation into the seventh event revealed that the bolt mechanism was defective, and-the gate was hard to open and close properly due to a metal piece on the gate at the locking mechanism that was fouling the metal door jamb. Following the event, the licensee began requiring HP personnel to ,

open and close all gates in and out of high radiation area .

During the inspection exit meeting,'the licensee was informed that the

high- radiation door that was found un-secured on September 20, 1990, appeared to be another violation of licensee TS'6.12.2. Upon review of the events associated with the September 20, 1990 violation, other examples previously identified, and- the licensee's_ corrective actions for those

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events, and the merit of possible escalated enforcement actions; the decision was made to identify the additional TS 6.12.2 violation as a violation resulting from failure to take adequate and timely corrective actions for previously identified TS 6.12.2 violations (50-324/90-43-01). The URI (50-324/90-37-01) associated with this violation was close ,

. E'xit Interview The inspection scope and findings were summarized on October 19, 1990, with those persons indicated in Paragraph 1 above. The inspectors ,

described the areas inspected and discussed in detail the inspection i findings. At the exit meeting the licensee was notified that failure to maintain access control requirements specified in= licensee TS 6.12, for a a high radiation area having' a general area dose-rate greater than I rem per hour in the licensee's Unit 2 Turbine Building on September 21, 1990, appeared to be the seventh violation of the requirement within the last i 17 months. No dissenting connents were received from the license l During a telephone conversation on November 2, 1990, between G. Cheatham of Carolina Power and Light and F. Wright of. the NRC, the licensee was {

informed that failure to take adequate and timely corrective actions to l preclude an additional violation- of: licensee TS 6.12.2 requirements, on ,

September 20, 1990, appeared to be'a violation of 10 CFR 50 Appendix B, I Criterion XVI, Corrective Action. Again, no dissenting comments were received from the license l

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