IR 05000413/1987031
| ML20236B537 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 10/16/1987 |
| From: | Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236B500 | List: |
| References | |
| 50-413-87-31, 50-414-87-31, IEIN-86-055, IEIN-86-103, IEIN-86-107, IEIN-86-55, IEIN-87-003, IEIN-87-007, IEIN-87-019, IEIN-87-028, IEIN-87-031, IEIN-87-19, IEIN-87-28, IEIN-87-3, IEIN-87-31, IEIN-87-7, NUDOCS 8710260231 | |
| Download: ML20236B537 (12) | |
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Report Nos:
50-413/87-31 and 50-414/87-31 Licensee: Duke Power. Company 422 South Church Street g
Charlotte, NC 28242
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Docket-Nos.:
50-413 and 50-414 License Nos.:
NPF-35 and NPF-52 Facility Name:
Catawba 1 and 2 Inspection Conducted:
September 14-18, 1987 Inspectors:
ObudJth
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C. H..Bassett Date Signed Approved by:
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C. M. liosey, Sect on Chief.
Date Signed Division of Radia on Safety and Safeguards SUMMARY Scope:
This was' a routine, unannounced inspection in the area of radiation protection including:
organization and management control; training and
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qualifications; external exposure control;. internal exposure control; the program to maintain exposures as low as reasonably achievable (ALARA); the solid radioactive waste program and followup on a previous enforcement item and IE Notices.
Results:
One violation was identified:
failure to adhere to radiological control procedures for personnel contamination monitoring and completion of daily dose cards.
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'3 8710260231 s71019 PDR ADDCK 05000413
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REPORT DETAILS l.'
Persons Contacted L
Licensee Employees
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- R. F. Wardell, Superintendent of Technical Services
- G. T. Smith, Superintendent of Maintenance
- W. P. Deal, Station Health Physicist
- J. W. Cox, Station Training Manager H.; F. McInvale, Surveillance and Control Coordinator G..T. Mode,. Support Functions Coordinator j
- R. L. Clemmer, Shif t Coordinator j
- G. G. Barrett, Training Supervisor S. W. Rodgers, Radwaste Chemistry Coordinator.
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T.'W. O'Donahue, Surveillance and Control' Supervisor D. V.' Baysinger, Shift Supervisor M. C. Couch, Dose Records Control Supervisor-
- M. A. Cote, Compliance ~ Specialist
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- M. C. Criminger, Quality Assurance / Surveillance
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- B. R. Smith, Quality Assurance / Surveillance
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J. Isaacson, Staff Health Physicist G. L. Courtney, Staff Health Physicist
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Other licensee employees contacted included engineers, -technicians,
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security office ' members and office personnel.
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. Nuclear Regulatory Commission
- P. K. Van Doorn, Senior Resident Inspector-
- M. J. Lesser, Resident Inspector l
t 2.
Exit Interview l
The -inspection scope and findings were summarized on September 18, 1987, with those persons indicated in Paragraph 1 above.
The inspector described the areas inspected and discussed in detail an apparent violation for failure to adhere to radiation control procedures with two examples (Paragraphs 6 and 8).
The licensee acknowledged the inspection i
findings and took no exceptions.
The licensee did not identify as i
proprietary any of the material provided to or reviewed by the inspector
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during this inspection.
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Licensee Action on Previous Enforcement Matters (Closed) Violation 50-413/87-11-01, Failure to adhere to radiation control l
- procedures for documentation of radiological surveys of radioactive material shipments.
The inspector reviewed the licensee's response dated June 1,1987, and verified that the corrective actions specified in the response had been completed, j
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-2 4.
- Organization and Management Controls (83722)
a.
Organization-The licensee is required by Technical Specification (TS) 6.2.2 to
' implement the facility organization specified in TS Figure 6.2-2.
The responsibility, authority and other management controls necessary for establishing and maintaining a health. physics program for the facility are outlined in Chapters 12 and 13 of the Final Safety Analysis Report (FSAR).
TS 6.2.3 specifies the composition of the Catawba Safety Review Group (CSRG) and delineates its functions and authority.
Regulatory Guide 8.8 specifies certain functions and responsibilities to-be assigned to the Radiation Protection Manager and radiation protection responsibilities to be assigned to line management.
The inspector reviewed the licensee's plant organization and lines of authority as they relate to the radiation protection progra.a and verified that the licensee had not made organizational changes which would adversely affect the ability of-the licensee to implement the critical elements.of the program.
No violations or deviations were identified, b.
Staffing Technical Specification 6.2.2 specifies minimum staffing for the plant.
FSAR Chapters 12 and 13 outlines further details on staffing.
The 1.nspector reviewed the health physics organization and staffing with the Station Health Physicist.
The attrition rate, use of contractor health physics technicians, current staffing levels and qualifications were discussed.
At the time of the inspection, 102 staff positions were authorized and all but one were filled. The licensee indicated that, at the end of the Unit 2 outage in March 1988, the 20 contractor technicians who had been used for the past year to augment the permanent staff would be terminated.
No violations or deviations were identified, c.
Controls The inspector reviewed selected licensee reports used to identify and i
correct radiological deficiencies and problems.
These reports I
included:
(1) Health Physics Problem Reports which could be filed by l
L anyone noting a minor radiological concern, (2) Preliminary j
Investigation Reports which are used to handle problems which affect i
the station's operations, and (3) Radiological Incident Investigation and Accountability (RIIA) Reports which are used to detail specific
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incidents usually involving such items as personnel contaminations.
No violations or deviations were identified.
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Outage Preparations The licensee indicated that preparations for the upcoming outage had started six months previously and that most aspects were on schedule.
Additional health physics support had been obtained and
.140 contractors, including supervisors and technicians, were scheduled to be onsite during the peak workload period of the outage.
No violations or deviations were identified.
5.
Training and Qualifications (83723)
a.
General Employee Training (GET)
The licensee is required by 10 CFR 19.12.to provide basic radiation protection training to workers.
Regulatory Guides 8.13, 8.27 and 8.29 outlihe topics that should be included in such training.
Chapters 12 and 13 of the FSAR also contain further commitments regarding training.
Upon reviewing selected Radiological Incident Investigation and Accountability reports, the inspector noted that certain individuals had been involved in more than one contamination event.
The inspector reviewed the training records of these workers and verified that their GET was current.
Through discussions with both training department personnel and the Station Health Physicist it was determined that, although retraining of an individual was an option that management could use to correct deficiencies in a person's knowledge level, no such problems had been noted to date.
The l
licensee indicated that training was generally adequate but other factors such as attitude and responsibility were the major contributing factors to most radiological problems.
l The inspector also reviewed the Respiratory Protection Training i
program and reviewed the training records of selected individuals who l
had been issued respirators based on entry into a controlled area
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under a radiation work permit that required their use, j
No violations or deviations were identified.
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Supervisor and Health Physics Technician Qualification and Training
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Technical Specification 6.3 requires that each member of the facility
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staff meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions.
W The inspector reviewed the qualifications of a recently appointed l
health physics supervisor and those of selected station and j
contractor health physics technicians and verified that the j
applicable technical training and working experience requirements had j
been met.
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l The inspector also reviewed the medical qualifications of those j
individuals whose respiratory protection training records had been j
checked to verify that the requirements for an annual physical or medical evaluation had been satisfied.
No violations or deviations were identified.
l 6.
External Exposure Control and Dosimetry (83724)
a.
Dosimetry 10 CFR 20.101(b)(3) requires licensees to determine an individual's accumulated occupational exposure to the whole body on a Form NRC-4 or its equivalent prior to permitting the individual to exceed the limits of 10 CFR 20.101(a).
The inspector reviewed selected occupational exposure histories for individuals who had exceeded the 10 CFR 20.101(a) values and determined that exposure histories were being completed and maintained as required.
10 CFR 20.202 requires each licensee to supply appropriate personnel
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monitoring equipment to specific individuals and require the use of i
such equipment.
During plant tours, the inspector observed workers j
wearing thermoluminescent dosimeters (TLDs) and pocket dosimeters (PDs) as required.
No violations or deviations were identified.
b.
Dosinwtry Results The inspector reviewed the licensee's Form NRC-5 equivalent printout showing exposure accumulated through September 16, 1987. The results included TLD results through August and PD updates to the TLD totals through September 16, 1987.
The inspector verified that the radiation doses recorded for monitored personnel were within the limits of 10 CFR 20.101.
No violations or deviations were identified.
c.
Skin Dose 10 CFR 20.101(a) states thet no licensee shall possess, use or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter from radioactive material and other sources of
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l radiation a total occupational dose in excess of 7.5 rem to the skin of the whole body or 18.75 rem to the extremities.
Through review of RIIA Report Number 87-53 dated August 16, 1987, it
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was noted that an individual had been contaminated on the upper chest with a " hot particle" during the removal of the Unit 2
"D" steam generator diaphragm.
The licensee postulated that the contamination _ _ _ _ _ _ _ _ _ _ _ _ _.
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occurred during removal of the personal protective clothing (PCs)
which consisted of a wet suit and air-supplied hood worn over cloth coveralls and hood along with shoe covers and rubber gloves.
The particle read 1 millirem per hour (mr/hr) of gamma radiation and 44 mr/hr of beta radiation when measured with an ionization chamber.
A qualitative analysis of the particle showed it to be composed of g
cobalt-58 and -60, chrominum-51, iron-59 and manganese-54.
Although i
the licensee theorized that the contamination occurred while the individual was removing his PCs, the time used to calculate the resultant dose to the skin was 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> which was the length of time the worker.had spent on the job.
The licensee calculated the skin dose to be 154 millirem based on the particle's beta radiation dose rate and the length of time the individual was on the job.
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discussions with the inspector concerning the adequacy of the dose evaluation, the licensee indicated they would reinvestigate the f
incident and reevaluate the resultant skin dose.
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On October 13, 1987, the inspector reviewed Revision 1 of RIIA Report Number 87-53, dated October 9,1987.
The licensee determined that the worker had become contaminated while removing his PCs and that the total time the particle was on the skin was 45 minutes.
Using the methodology suggested in Section A.6, NUREG/CR-4418, Dose Calculation for Contamination of the Skin Using the Computer Code VARSKIN, published August 1987, the licensee determined the individual's exposure to the skin was 1342 millirem.
This methodology pennits the calculation of skin dose from an instrumnt reading.
The corrected exposure was added to the person's third quarter dose giving him a total quarterly dose of 2061 millirem.
The inspector also reviewed the licensee's procedure for determining dose to the skin, HP/0/8/1009/02, Investigation of Possible Overexposure, Personnel Contamination, and/or Unusual Radiological Occurrences, dated June 25, 1987.
It was noted that the procedure had a worksheet which was to be used to calculate dose to the skin.
The worksheet was set up to be used for general area contamination of the skin when the level of contamination was measured in counts per minute using a frisker. The procedure did not address the problem of hot particle contamination, the means to be used to retrieve and analyze a particle or the method or methods to be used to calculate the resultant exposure.
The licensee indicated that the problem of hot particles had recently been addressed and that the procedure dealing with skin contamination was going to be revised.
The inspector indicated that the procedure revision would be an inspector followup item and would be reviewed during a subsequent inspection (50-413,414/87-31-01).
No violations or deviations were identified.
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6 d.
Radiation Work Permits (RWP)
The inspector reviewed selected Standing RWPs and specific job
- overage RWPs to verify that requirements for surveys, protective clothing, air sampling and dose arsessment, if necessary, were adequate.
While reviewing RWP 87-479, Removal and Repair or Replacement of Unit 1 ENB Detector, it was noted that beta dose to the skin was assigned due to exposure of workers to xenon gas in the work area.
Upon comparing a computer printout listing names of persons working under RWP 87-479 on August 24, 1987, with a printout of beta dose assigned to workers, it was noted that several people had been assigned dose whose names did not appear on the list of people having worked under RWP 87-479.
Further investigation revealed that part of the problem resulted from the fact that some of the personnel involved were working twelve hour shifts.
During their shift the workers would fill out a daily exposure time card which reflected time spent on a particular RWP and the exposure received for the shift.
The result was that, occasionally, a worker's time spent on the job and the dose received would be attributed to one day when it was technically received on l
two different days.
However, it was also noted that two individuals did not fill out the required daily exposure time cards for August 24, 1987.
l Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Catawba Nuclear Station Directive 3.8.6 (TS), Radiation Exposure Control, Revision 13, dated March 12, 1987, requires in Section 2.7 that all individuals complete a Daily Exposure Time Record Card (DETRC) for each entry)into the RCA (radiation control area)/RCZ (radiation control zone and each change of RWP/SRWP.
Failure of two individuals to complete the DETRC as required was identified as an apparent violation of TS 6.11(50-413,414/87-31-02).
7.
Internal Exposure Control (83725)
a.
Air Sampling and Assessment 10 CFR 20.103 establishes the limits for exposure of individuals to concentrations of radioactive materials in air in rest ricted areas.
This section also requires that suitable measurements of concentrations of radioactive material in air be performed to detect and evaluate the airborne radioactivity in restricted areas.
The inspector reviewed the results of air samples taken in support of valve work in Unit 2 Reactor Building and Auxiliary Building governed by RWPs87-470 and 87-471 and work on a detector in Unit 1 Reactor
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Building governed by RWP 87-479.
The air samples had been evaluated for alpha, beta, and gamma activity.
No violations or deviations were identified.
b.
Respiratory Protection Program 10 CFR 20.103(b) requires that, when it is impracticable to apply process or engineering controls to limit concentrations of radioactive materials in air below 25 percent of the concentrations specified in Appendix B, Table 1, Column 1, other precautionary measures should be used to maintain the intake of radioactive l
material by any individual within seven consecutive days as far below 40 Maximum Permissible Concentration-hours (MPC-hrs) as is reasonably achievable.
By reviewing records and through observations and discussions with licensee representatives, the inspector evaluated the respiratory protection program, including training, fit testing, MPC-hr assignments, quality of breathing air and the issue, use, decontamination and storage of respirators.
Review of the MPC-hr assignments for selected individuals revealed that all exposures were well under the 40 MPC-hr per week control level.
No violations or deviations were identified.
8.
Control of Radioactive Material, Surveys, and Monitoring (83726)
a.
Surveys The licensee is 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.
Survey methods and instrumentation are outlined in FSAR Chapter 12, while TS 6.11 provides requirements for adherence to written procedures.
During plant tours, the inspector examined radiation levels and contamination survey results posted outside selected rooms and cubicles.
The inspector also performed independent radiation level surveys of selected areas and compared them with licensee survey results.
No violations or deviations were identified.
b.
Frisking Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirement of 10 CFR 20 and be approved, maintained and adhered to for all operations involving personnel radiation exposures.
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Catawba Nuclear Station Directive 3.8.3, Contamination Prevention, Control and Decontamination Responsibilities, Revision 21, dated July 2,1987, requires in Section 4.6.2.2 that personnel perform a survey for contamination when leaving a radiation control area (RCA).
If frisking just the hands and feet, a minimum frisk of 40 seconds is required.
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During tours of de plant, the inspector observed the exit of workers and movement of materials from the RCA to the clean areas of the
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plant to determine if proper frisking was being performed by workers and proper fixed and transferable contamination surveys were being performed on materials.
No problems were noted with material surveys; however, personnel frisking deficiencies were noted.
During the time period from 4:20 until 5:00 p.m. on the evenings of September 14,15, and 17,1987, and from 2:00 until 2:30 p.m. on September 16, 1987, the inspector 7bserved licensee personnel leave the RCA from the exit located at tae top of the spiral stairway on the 609' elevation.
In other location of the facility, the licensee had installed personnel contamination monitors which monitored an individual's hands and feet for approximately 10 seconds but, at this exit there were only two portable friskers with hand held probes for personal contamination surveys.
During the aforementioned time periods, twelve people were observed frisking at the exit.
Ten of the twelve people performed a hands and feet frisk of approximately 20 to 25 seconds; the other two individuals performed a hands and feet frisk of approximately 50 to 60 seconds.
No one was noted leaving any controlled area without performing some type of personnel contamination survey.
Failure of personnel to frisk hands and feet for the minimum time required was identified as a second example of an apparent violation of TS 6.11 (50-413, 414/87-31-02).
9.
Maintaining Occupational Exposures As Low As Reasonably Achievable (ALARA)
(83728)
a.
The ALARA Program 10 CFR 20.1(c) states that licensees should make every reasonable effort to mainta'a radiation exposures as low as reasonably achievable, taking into account the state of technology, the economics of improvements in relation to benefits to the public health and safety and other societal and socioeconomic considerations.
The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including the station's ALARA goals and objectives, the effectiveness in setting and meeting ALARA goals, i
participation by different station groups in the ALARA program and the functions of the onsite ALARA group.
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No violations or deviations were identified.
b.
The ALARA Group The onsite ALARA group is composed of one supervisor, 3 licensee technicians and 2 contractor technicians.
The group's primary responsibilities are to help estimate exposure for jobs based on
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historical data and experience, to help establish goals for the station and the various departments and to track progress toward those goals and help remedy problems as they are noted.
Pre-job reviews are also performed when total job exposure is expected to exceed one person-rem.
It was noted that all jobs receive at least a limited an ALARA review because those planning the work are required -
to complete a pre-plan worksheet which includes ALARA considerations.
No violations or deviations were identified.
c.
The ALARA Committee and Problem Reports in addition to the ALARA group, the station has a 16-member ALARA Committee composed of representatives from various departments.
Each representative has the authority to make commitments for their respective department.
The committee meets quarterly and functions to review the results of exposures, releases and problems related to outage or maintenance work. The committee also reviews ALARA Problem Reports which can be used to detail problems or make suggestions for
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improvements.
The ALARA Problem Report program was initiated in May 1984.
Twenty-five reports have been received since that date but i
only two during 1987.
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d.
The ALARA Incentive Program
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l The licensee indicated that steps were being taken to strengthen and i
stimulate interest in the ALARA program.
Incentives are being given for the submission of substantive ALARA Problem reports or suggestions and other ideas are also being considered to improve the program.
No violations or deviations were identified, e.
Goals and Objectives The inspector discussed the person-rem goals and objectives for 1986 and 1987 with the Station Health Physicist.
The licensee's goal for 1986 was 540 person-rem.
However, due to various actions taken to limit exposure tuch as the use of temporary shielding and mock-up training, the actual total exposure was 284 person-rem. The licensee indicated that the original goal or 1987 was 445 person-rem which included a refueling outage but, due to the addition of unanticipated
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jobs during the Unit 1 outage and the Unit 2 outage originally scheduled for 1988 being moved to the last two weeks of 1987, the ALARA Group had proposed an increase in the 1987 goal to 525 person-rem.
As of September 14, 1987, the licensee had expended 89 person-rem, all prior to the scheduled outages.
No violations or deviations were identified.
10.
Solid Radioactive Waste (84722)
a.
Storage Areas 10 CFR 20.203(e) requires that each area or room in which licensed material is used or stored in amounts in excess of ten times the quantities listed in Appendix C be posted as a radioactive material area.
During plant tours, the inspector verified that radioactive materials storage areas were properly posted.
No violations or deviations were identified, b.
Waste Characterization and Stability 10 CFR 61.56 specifies the waste characteristics and stability requirements for low level radioactive waste.
Through discussions with licensee representatives and review of selected records, the inspector determined that waste stability, when required, was achieved by use of approved containers or by solidification.
Solidification was performed by a vendor and included formation and testing of a demonstration or sample product prior to each batch l
processing.
Dewatering was also performed by a vendor and final l
verification that liquid content met NRC and waste burial site
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criteria was accomplished by pumping off all free standing liquid and l
visually verifying that the liquid remaining is calculated to be less l
than the amount allowed for shipment.
l No violations or deviations were identified.
c.
Radwaste Shipments Through discussions with licensee representatives and records review, I
it was noted that 6,804 cubic feet (ft') of solid radioactive waste containing 13.26 curies of activity had been shipped from the facility during 1986.
Through September 15, 1987, the licensee had I
l made 11 shipments consisting of 3,767 f t3 of waste containing 104 curies of activity.
l No violations or deviations were identified.
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11. Audits (83724,83725,83726,83728,84722)
The licensee is required by TS 6.5 to perform audits of radiological control. operations.
The inspector reviewed selected audits performed by the corporate office and selected surveillance performed by site Quality Assurance personnel.
The audits and surveillance appeared to be of adequate depth and were performed by personnel with appropriate technical backgrounds.
No violations or deviations were identified.
12.
IE Information Notices (92717)
The inspector determined that the following NRC Information Notices (IENs)
have been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that actions, as appropriate, l
were taken or scheduled, a.
IEN 86-55:
Delayed Access to Safety-Related Areas and Equipment during Plant Emergencies b.
IEN 86-103:
Respiratory Coupling Nut Assembly Failures c.
IEN 86-107:
Entry Into PWR Cavity with Retractable Incore Detector Thimbles Withdrawn d.
IEN 87-03:
Segregation of Hazardous and Low-Level Radioactive Wastes
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IEN 87-07:
Quality Control of On.,ite Dewatering / Solidification i
Operations by Outside contractors
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IEN 87-19:
Perforation and Cracking of Rod Cluster Control
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Assemblies (Specifically for all Westinghouse PWRs)
9 IEN 87-28: Air Systems Problems at U.S. Light Water Reactors
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IEN 87-31:
Blocking, Bracing and Securing of Radioactive Materials Packages in Transportation I
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