IR 05000413/1987040
| ML20237A763 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/04/1987 |
| From: | Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20237A713 | List: |
| References | |
| 50-413-87-40, 50-414-87-40, NUDOCS 8712150237 | |
| Download: ML20237A763 (12) | |
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I UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11 l
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101 MARIETTA STREET, N.W.
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ATL ANT A, GEORGI A 30323
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DEC 101997 Report Nos.:
50-413/87-40 and 50-414/87-40 Licensec:
Duke Power Company i
422 South Church Street Charlotte, NC 28242 Facility Name:
Catawba Nuclear Station Docket Nos.:
50-413 and 50-414 License Nos.:
NPF-35 and NPF-52 Inspection conducted:
November 16-20, 1987 (LLat
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Inspector:
_C. H. Bassett Date S'igned Accompanying Personnel:
R. B. Shortridge
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/97 Approved b :
a U M. Hosey, Section Chief Da,te Sfgned'
Division of Radiation Safety and Safeguards h
SUMMARY Scope: This was a routine, unannounced inspection in the area of radiation protection including:
organization and management controls; external exposure control; internal exposure contrel; control of radioactive materials contamination, surveys and monitoring; and the health physics aspects of the current outage.
Results:
Two violations were identified:
failure to provide adequate written procedures for controlling contaminated tools and Tailure to post a Notice of Violation as required.
An additional example of a violation described in Inspection Report Nos. 50-413/87-31 and 50-414/87-31 for failure to adhere to radiological control procedure for personnel monitoring was also identified.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J. H. Hampton, Manager, Catawba Nuclear Station (CNS)
- G. T. Smith, Superintendent, Maintenance
- J. W. Glenn, Production Department Engineer
- W. R. McCollum, Superintendent, Scheduling
- B. R. Smith, Quality Assurance / Surveillance
- D. S. Miller, Quality Assurance Staff
- W. P. Deal, Station Health Physicist
- C. L. Hartzell, Compliance Engineer
- W. W. McCollough, Mechanical Maintenance Engineer
- C.
E. Muse, Unit 2 Coordinator
- J. R. Ferguson, Unit 2 Schedule Engineer H. F. McInvale, Surveillance and Control Coordinator G. T. Mode, Support Functions Coordinator T. W. O'Donahue, Surveillance and Control Supervisor M. A. Cote', Compliance Specialist G. G. Barrett, Training Supervisor S. L. Cox, Training Specialist
- M. A. Ruhe, Staff Health Physicist
- C, D. Long, Tool Control Specialist Other licensee employees contacted included craftsmen, engineers, technicians, mechanics, security office members and office personnel.
Nuclear Regulatory Commission P. K. VanDoorn, Senior Resident Inspector
- M. H. Lesser, Resident Inspector
- K. N. Jabbour, Project Inspector-HQ
- Attended exit interview 2.
Exit interview The inspection scope and findings were summarized on November 20, 1987, with those persons indicated in Paragraph 1 above.
The inspector described the areas inspected and discussed in detail an apparent i
violation for failure to develop and impleinent a procedure for storage of too?s with loose surface contamination (Paragraph 7), and an apparent violation for failure to post a Notice of Violation (Paragraph 4).
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additior>al example of an apparent violation, described in Inspection
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Report Nos. 50-413/87-31 and 50-414/87-31, for failure to adhere to J
radiological control procedures for personnel hionitoring for contamination was aise discussed.
Due to the apparent inadequate corrective actions taken to correct Violation 87-31-02, the licensee was requested to submit
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a supplemental response to the violation within 30 days.
During a phone l
call on November 25, 1987, between the CNS Compliance Engineer and the l
inspector, the licensee made an oral commitment to submit a supplemental l
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response by December 11, 1987.
The licensee acknowledged the inspection finding:; and took no exceptions.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (0 pen) Violation 50-413/87-31-02, Failure to perform adequate personnel
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monitoring.
The NRC reviewed the licensee's response dated November 17, 1987, and determined that the response was inadequate in that the corrective actions proposed by the licensee would not result in j
improvement of personnel frisking.
In addition, during this inspection
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further problems were noted with personnel performing whole body frisks in accordance with station directives.
4.
Organization and Management Controls (83722)
a.
Organization l
The licensee is required by Technical Specification (TS) 6.2.2 to
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implement the facility organization specified in TS figure 6.2-2.
The responsibilities, authority and other management controls necessary for establishing and maintaining a health physics program
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for the facility are outlined in Chapters 12 and 13 of the Final l
Safety Analysis Report (FSAR).
The inspector reviewed the licensee's plant organization as well as the responsibilities, authority and controls of. management as they l
relate to the facility radiation protection program.
The inspector verified that no organizational changes had been made which would adversely affect the ability of the licensee to implement the critical elements of the program and discussed with licensee health physics representatives the support received for the radiation protection program.
No violations or deviations were identified.
b.
Staffing Technical Specification 6.2.2 specifies the minimum staffing for the facility.
FSAR Chapters 12 and 13 furthcr outlines details on staffing.
The inspector reviewed the staffing level of the station health physics organization with the Station Health Physicist, as well as the number of contractors onsite to assist with the Unit 1 outage.
At the time of the inspection,101 of the 102 authorized health physics positions were filled.
Also, there were 148 health physics contract personnel, including supervisory as well as junior and senior technicians, on hand for the outage work in progress.
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was anticipated that a majority of the contractors would be held over or requested to return for the upcoming Unit 2 outage scheduled to begin around December 18, 1987.
No violations or deviations were identified.
c.
Controls The inspector reviewed selectcd licensee reports used to identify and l
correct radiological proble's and deficiencies including Health
Physics Problem Reports and Radiological Incident Investigation and Accountability (RIIA) Reports.
The problem reports dealt mainly with i
failure of personnel to turn in dose cards and leave their dosimetry
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in the designated location.
The RIIA Reports were used primarily to document personnel contaminations.
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No violations or deviations were identified.
d.
Posting
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I 10 CFR 19.11(a)(.4) requires each licensee to post current copies of l
any Notice of Violation involving radiological working conditions.
Part 19.11(e) requires that such documents remain posted for a minimum of 5 working days or until action correcting the violation
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I has been completed whichever is later.
l During the week of November 16-20, 1987, the inspector observed the bulletin boards at the entrance to the restricted area and at the entrance to the station cafeteria where documents are generally posted in compliance with 10 CFR 19.11.
No Notice of Violation was noted for Violation 87-31-02 concerning failure to adhere to i
procedures for frisking as described in Inspection Report Nos. 50-413/87-31 and 50-414/87-31 dated October 19, 1987. Licensee representatives indicated that no Notice of Violation had been posted
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even though the corrective ' actions for the violation were not I
scheduled to be completed until January 1988.
l Failure to post a Notice of Violation involving radiological working conditions was identified as an apparent violation of 10 CFR 19.11
(50-413,414/87-40-01).
I 5.
External Exposure Control and Dosimetry (83724)
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a.
Personnel Monitoring Devices 10 CFR 20.202 requires each licensee to supply appropriate personnel monitoring devices to specific individuals and require the use of such equipment.
During tours of the Unit 1 Reactor Building, the Auxiliary Building, and other areas of the Radiation Coritrol Area (RCA), the inspector observed workers wearing appropriate personnel monitoring devices as required.
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l No violations or deviations were identified.
b.
Radiologically Controlled Areas 10 CFR 20.203 specifies posting and control requirements for l
radiation areas, high radiation areas, airborne radioactivity areas, and radioactive material areas.
During plant tours, the inspector observed the licensee's posting and
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control of radiation, high radiation, airborne radioactivity and radioactive material areas.
The inspector also verified that various high radiation areas in the Auxiliary Building were being maintained locked as required.
No violations or deviations were identified.
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Personnel Exposure Control I
The licensee is required by 10 CFR 20.101 and 20.102 to maintain workers' doses below specified levels.
The inspector reviewed selected occupational exposure histories of contractor and licensee personnel and verified that the licensee was requiring a completed Form NRC-4 or its equivalent to be maintained on file prior to permitting an individual to exceed the limits specified in 10 CFR 20.101(a).
The inspector also reviewed the Form NRC-5
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equivalent printoJt for the plant and determined that the radiation l
exposures recorded were within the quarterly limits specified above.
No violations or deviations were identified.
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Dosimetry Reports The inspector reviewed selected Self-Reading Pocket Dosimeter (SRPD)
l and Thermoluminescent Dosimeter (TLD) Discrepancy Reports and Lost,
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Offscale or Abnormal TLD/SRPD Reports.
The reports and subsequent
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dose assignments made following appropriate investigations of the occurrences appeared adequate. The inspector reviewed investigations of possible overexposure which had occurred since the preceding i
inspection but no exposures exceeding local administrative or i
regulatory limitt had occurred.
No violations or deviations were identified.
l e.
Skin Dose Assessment 10 CFR 20.101(a) states that 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 anc other sources of 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.
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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.
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CNS Directive 3.8.3, Contamination Prevention, Control and Decontamination Responsibilities, Revision 21, dated July 2, 1987,
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requires in Paragraph 4.6 that personnel leaving a contaminated area (
frisk for a minimum of three minutes at the first available frisker.
l CNS Directive 3.8.8, Radiological Work Practices, Revision 15, dated December 3, 1986, requires in Paragraph 2.1 that all employees exercise good radiological work practices and comply with posted Radiation Work Permits (RWPs).
Through review of a not yet completed RIIA Report No.87-147, dated
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November 10, 1987, it was noted that an individual had been
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contaminated on the upper chest with a hot particle during work under
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RWP 87-147 which entailed the reinstallation of snubbers on the 552' elevation and in the pipe chase in Unit i Lower Containment.
The licensee postulated that the contamination occurred during the l
time period the individual was working in lower containment and may j
have resulted from improper wearing of protective clothing (PCs).
l (At one point in the job, it was pointed out to the person that the zipper on his PCs was down.)
After finishing his work, the individual left Unit 1 Lower Containment but failed to perform an
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adequate whole body frisk.
It was not until about an hour after he had exited the contaminated area that the hot particle was found when the individual alarmed a portal monitor as he tried to exit the restricted area.
l The particle read 7 millirad per hour (mrad /hr) using the open window of an ionization chamber and 0.3 millirem per hour (mr/hr) closed window.
A qualitative analysis of the particle showed it to be composed of approximately 3.638 E-1 microcuries of Cobalt-60.
The licensee determined that the total exposure time was 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and, by using the methodology suggested in Section A.6 of 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 approximately 5,378 millirem.
This calculated exposure, when added to the person's fourth quarter skin dose of 512 millirem as measured by TLD, resulted in a total exposure to the skin of 5,890 millirem.
Since no administrative control level or regulatory limit was exceeded, no further actions were required.
The licensee did, however, restrict the individual from further work in the RCA during the remainder of the quarter and also initiated the installation of a portal monitor located outside the change room on the 594' elevation.
The licensee was informed that failure to exercise good radiological work practices for the proper use of PCs and failure to adequately I
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i monitor for personnel contamination would normally be considered as apparent violations of TS 6.11.
However, the NRC Enforcement Policy,
10 CFR 2, Appendix C, states that a Notice of Violation will j
generally not be issued for violations identified by the licensee, if I
(1) it was identified by the licensee; (2) it fits in Severity Level I
IV or V; (3) it was reported, if required; (4) it was or will be corrected; and (5) it was not a violation that could reasonably be expected to have been prevented by the licensee's corrective actions for a previous violation.
The inspector stated that these apparent violations met the criteria specified in 10 CFR 2, Appendix C and j
would be considered licensee identified.
The inspector indicated i
that the corrective actions to be taken by the licensee would be i
reviewed during a subsequent inspection (50-413, 414/87-40-02).
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Radiation Work Permits (RWPs)
The ins i
(SRWPs) pector reviewed selected Standing Radiation Work Permits governing routine, repetitive jobs and selected RWPs covering
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specific jobs related to the Unit 1 outage.
The SRWPs and RWPs l
reviewed included:
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87-6, Rev.1 Restricted Area Decon Work j
87-488, Unit 1 Reactor Building Snubber Surveillance and
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Operability Inspection for Tech Specs87-508, Unit 1 Reactor Building - All Work Associated with
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(AWAW) Decon of Lower Containment
87-540, Unit 1 Reactor Building Steam Generators A&D Shot j
Peening j
87-559, Unit 1 Upper Head Injection (UHI)-AWAW Cutting and
Removing UHI Piping and Installing Caps in UHI Building l
87-569, Unit 1 Reactor Building - AWAW Steam Generator Sludge
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Lancing
'87-580, Unit 2 Reactor Building - AWAW Leak Repair on Various Valves in Lower Containment The RWPs were reviewed with respect to radiation monitoring, radiation and contamination surveys, airborne monitoring and j
dosimetry.
The surveys, monitoring and dosimetry appeared adequate.
No violations or deviations were identified.
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1 6.
Internal Exposure Control and Assessment (83725)
I a.
Engineering Controls and Respiratory Protection j
10 CFR 20.103(b)(1) requires that the licensee use process or other engineering controls to the extent practicable to limit I
concentrations of radioactive materials in the air to levels below
those which delimit an airborne radioactivity area as defined in 20.203(d)(1)(ii).
During plant tours, the inspector observed various engineering I
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These included the use of temporary ventilation systems, containment
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enclosures, continuous flow hoods and respirators.
The inspector I
discussed the use of respiratory equipment with licensee personnel to i
ensure that medical evaluations and fit testing were performed prior j
to respirator use.
Selected personnel records were reviewed to ensure that the required training, medical evaluations and whole body i
l counts were documented.
b.
Intake Assessment 10 CFR 20.103(b) requires that when an individual exceeds 40 Maximum i
Permissible Concentration-hours (MPC-hours) in any consecutive seven day period the licensee shall make such evaluations and take such actions as necessary to assure against recurrence.
Through records review and discussions with licensee representatives, it was determined that, during the fourth calendar quarter, no individual had been allowed to reach the 40 MPC-hour action limit or the facility's 35 MPC-hour administrative control.
The inspector reviewed results of selected body burden analyses (BBA) or whole body counts which revealed that the maximum organ burden detected had been from 1 to 2 percent of the Maximum Permissible Organ Burden (MP08).
None of the BBAs required further evaluation. The inspector reviewed
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investigations of possible intakes of radioactive material that had l
occurred since the last inspection in September 1987.
None required
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assignment of MPC-hours which exceeded station administrative controls or regulatory limits, c.
Air Sampling 10 CFR 20.103 establishes the limits for exposure of individuals to concentrations of radioactive materials in air in restricted areas.
j Section 20.103 also requires that suitable measurements of (
concentrations of radioactive material in air be performed to detect j
and evaluate the airborne radioactivity in restricted areas.
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The inspector reviewed the results of selected air samples taken during the current outage.
The results indicated that the ' air
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samples had been evaluated for alpha, beta and gamma activity and analyzed to determine the specific isotopes present.
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No violations or deviations were identified.
7.
Control of Radioactive Materials cnd Contamination, ' Surveys and Monitoring
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(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.
Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978.
Procedures for contamination control are recommended by Paragraph 7.e.4 of Appendix A.
CNS Station Directive 3.8.3, Contamination Prevention, Control and Decontamination Responsibilities, Revision 21 dated July 2, 1987, requires in Section 4.5.1 that items outside of posted contaminated areas of the RCA be maintained with working limits for contamination of less than 1,000 dpm/100 cm2
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On November 16, 1987, the inspector performed a radiation and contamination survey on hand tools stored in the Hot Tool Room cool crib adjacent to the Unit 1 containment upper level access. The tool crib is used to store tools that have been used in a controlled area and is divided into two sections.
One section is for storage of tools with surface contamination greater than 1,000 dpm/100 cm2 and
fixed contamination less than 2 mrem /hr.
The other section is for storage of tools with loose contamination less than 1,000 dpm/100 cm2 and fixed contamination'less than 2 mrem /hr. Ten tools with readings
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from 5,000 counts per minute (cpm) to 14,000 cpm with a frisker were selected for survey for loose surface contamination.
Two of the 10 tools, which were stored on the clean side of the tool room, had loose surface contamination levels from 2,700 to 3,400 dpm/100 cm2 l
The licensee was informed of these findings and subsequently i
performed a more comprehensive survey of the tool room.
One other tool was found on the clean side of the tool room with loose surface contamination in excess of the working limits.
A review of Maintenance Procedure MP/0/B/7650-75, Issue and Control of Contaminated Tools and Equipment, dated February 25, 1985, which controls the operation of the Hot Tool Room, revealed that no direction is given for the control of contaminated tools with regard
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to storage within station working limits for contamination.
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the procedure does not contain adequate directions for the controlled l
storage of contaminated tools, the licensee was informed that this was an apparent violation of TS 6.8.1 for failure to maintain adequate procedures for contamination control (50-413, 414/87-40-03),
b.
Frisking Technical Specification 6.11 requires that procedures for personnel I
radiation protection be prepared consistent with the requirement of i
10 CFR 20 and be approved, maintained and adhered to for all l
operations involving personnel radiation exposures.
Catawba Nuclear Station Directive 3.8.3, Contaminat1on Prevention,
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Control and Decontamination Responsibilities, Revision 21, dated July 2,1987, requires in Section 4.6.2.2 that personnel perform a
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j survey for contamination when leaving a radiation control area.
In addition, Paragraph 4.6 requires that personnel leaving a i
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contaminated area perform personnel monitoring for contamination for
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a minimum of 3 minutes at the first available frisker. Each frisker I
I has a sign that contains the station's frisking requirements of 40 seconds for hand and feet and 3 minutes for the whole body as minimum times as well as the rate of speed for moving the probe.
From November 16-18, a total of 20 workers were observed performing personnel monitoring with hand held friskers.
Eight were observed at the lower level containment access, 2 were observed at the upper level containment access and -10 were observed at the change room frisker location.
None of the twenty individuals observed performed, hands and feet or whole body personnel monitoring for contamination
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in accordance with licensee requirements.
Workers exiting containment at the lower level access failed to perform whole body personnel monitoring at the nearest frisker and only monitored their hands and feet prior to dressing in street clothes.
f On November 19, 1987, two workers were found to have contaminated
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shoes at the green tag table area for clearing potentially
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contaminated tools from the RCA.
Neither individual performed
.i personnel monitoring for contamination at 2 closer frisker locations prior to walking a long distance to frisk at the clearing station.
Failure to properly monitor for personEl contamination and at the nearest frisker is a significant probler because licensee trending of personnel contaminations in the last 6 months revealed that between i
50 and 75 percent of personnel contaminations occur in clean
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(non-contamination controlled) areas of the radiologically controlled q
areas of the station.
A further example of this problem, as
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discussed in Paragraph 5 is the worker contaminated by a " hot particle" who apparently received additional exposure to the skin of the whole body because of failure to perform an adequate frisk at the nearest personnel contamination monitoring station after exiting a
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contamination controlled area.
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Failure of personnel to properly perform personnel contamination monitoring was identified as an additional example of a previous violation cited in Inspection Report Nos. 50-413/87-31 and 50-414/87-31.
c.
Hot Particle Control The inspector reviewed the licensee's Hot Particle Control Program.
In the past 2 1/2 months Catawba has experienced 8 hot particle contamination events.
While some events are of no exposure concern, such as a hot particle on a worker's shoe, others may contribute significantly to exposure.
Again, as mentioned in Paragraph 5, a worker was contaminated with a hot particle of Cobalt-60 and consec.uently received between 5 and 6 rem of exposure to his skin.
This and similar events indicate the need for additional emphasis in control of radioactive material.
The inspector and Station Health Physicist discussed various means of controlling hot particles which I
included:
(1) containment of hot particles at their source, (2) personnel compliance with station frisking requirements,
(3) specific training for health physics staff and technicians in i
en.gineered controls to contain hot particles and in techniques for their detection, and (4) specific training for maintenance personnel who work on open systems / components containing stellite.
8.
Maintaining Occupational Exposure As Low As Reasonably Achievable (ALARA)
(83728)
i 10 CFR 20.1(c) specifies that licensees should implement programs to
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maintain workers' doses ALARA.
Other recommended elements of an ALARA program are contained in Regulatory Guides 8.8 and 8.10.
Chapter 12 of the FSAR also contains licensee commitments regarding worker ALARA actions.
a.
Outage Accumulated Exposures The inspector reviewed the jobs being performed and the exposures l
accumulated during the outage to date with licensee representatives.
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The more significant jobs and the person-rem expended as of November
19, 1987, are as follows:
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Nozzle dam installation and removal 29.6 Snubber surveillance and inspection 12.4 Shot peening-setup and operation 67.7 Upper head injection piping cutting and removal 25.5 ISI of piping, welds, hangers, supports 7.1 NC (Reactor Coolant) pump seal replacement 15.2 Sludge lancing of steam generators 6.3 Miscellaneous valve work and instrument calibration 23.6 b.
Goals and Objectives l
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The person-rem goal for the outage was 323 and as of November 19, 1987, approximately 261 person-rem had been expended.
The annual goal for the facility was set at 445 while a total of 359 person-rem has been accumulated to date.
The personnel contamination rate has apparently decreased during 1987.
There were a total of 165 skin and l
clothing contaminations during 1986 while only 76 skin and clothing contaminations have been reported in 1987, No violations or deviations were identified.
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