ML20198N656

Insp Repts 50-324/97-14 & 50-325/97-14 on 971209-12. Violations Noted.Major Areas Inspected:Radiation Protection & Chemistry Controls,Miscellaneous Radiation Protection & Chemistry Issues & Mgt Meetings

ML20198N656
Person / Time
Site:	Brunswick
Issue date:	12/30/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198N643	List: IR 05000324/1997014 ML20198N639 ML20198N646 ML20198N656
References
50-324-97-14, 50-325-97-14, NUDOCS 9801210160
Download: ML20198N656 (7)

See also: IR 05000324/1997014

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4 l1 S. NUCLEAR REGULATORY COMMISSION

REGION 11 ,,

Docket Nos: 50-325, 50-324

License Nos: DPR-71. DPR-62

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

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9901210160 971230

PDR ADOCK 05000324

G PDR

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

e The radiation control program uas effectively implemented with good

occupational exposure controls c5 served during norndl plant operations,

(Section R1.1)

e The licensee's_off-site dose projection software. CPLDOSE, was evaluated

and determined to be functioning as designed with no flaws identified.

(Section R8.1)

e 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

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within the RCA, and were performing specific work activities on

appropriate RWPs.

The inspector reviewed total effective doses for radiation workers at s

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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

\ 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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b. Observati.gn s and Findinas

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 VIO Failure to control a Locked High Radiation Area

in accordance with procedure (Section R1.1)

50-325(324)/97-14-02 VIO 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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