IR 05000413/1988012

Insp Repts 50-413/88-12 & 50-414/88-12 on 880222-26. Violation Noted.Major Areas Inspected:Radiation Protection Area of Unit 2 Outage,Including Audits,Surveillances, Planning,Preparation,Training,Qualification & IE Notices

ML20151E831
Person / Time
Site:	Catawba
Issue date:	04/04/1988
From:	Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151E823	List: IR 05000413/1988012 ML20151E820
References
50-413-88-12, 50-414-88-12, IEIN-87-039, IEIN-87-39, NUDOCS 8804150396
Download: ML20151E831 (12)

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p". UNITED STATES g .j NUCLEAR REGULATORY COMMISSION -

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• REGION 11 g e,,,, 101 MARIETTA ST., ATLANTA. GEORGIA 30323

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APR 0 71988 Report Nos.: 50-413/88-12,50-414/88-12 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-413, 50-414 License No.: NPF-35, NPF-52 Facility Name: Catawba Inspection Conducted: February 22-26, 1988 Inspector: [/ b d C. H. Bassett Y [

Dite' Signed Accompanying Personnel: . Bermudez Approved by: -

M Y/Ph2 C. M. Hosey,' Sectio) Chief Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unanr.ounced inspection was conducted in the area of the radiation protection aspects of the Unit 2 outage including: audits and surveillances; planning and preparation; training and qualification; external exposure control; internal exposure control; control of radioactive materials and contamination, surveys and monitoring; the program to maintain exposures as low as reasonably achievable (ALARA) and followup on previous enforcement items and IE Notices, i

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Results: One licensee-identified violation was identified: failure of an individual to wear an integrating, alarming dosimeter in a high radiation area (HRA).

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REPORT DETAILS Persons Contacted Licensee Employees

• Bradley, Supervisor, Quality Assurance (QA)

• H. Barrow, Superintendent, Operations C. Couch, Supervisor, Dose Records Control G. Courtney, Supervising Scientist, Health Physics

• J. Cox, Manager, Station Training

• T. Crawford, Superintendent, Integrated Scheduling

• Deal, Station Health Physicist

• J. Hampton, Manager, Catawba Nuclear Station (CNS)

• T. Mathews, Manager, Design Engineering H. McInvale, General Supervisor, Surveillance and Control T. O'Donahue, Supervisor, Surveillance and Control

• T. Owen, Assistant Manager, CNS

• G. Smith, Superintendent, Maintenance R. Sorber, Health Physicist, General Office

• R. Wardell, Superintendent, Technical Services Other licensee employees contacted included engineers, technicians, operators, security office members, and office personne NRC Recident Inspector

• P. VanDoorn

• Attended exit interview Exit Interview The inspection scope and findings were summarized on February 26, 1988, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings including a licensee-identified violation for failure of a worker to wear an alarming dosimeter into a high radiation area (Paragraph 4.d.3). The inspector also indicated that violation 50-413/87-40-03 (Paragraph 3.b) would not be closed during this inspection since not all corrective actions had been implemented. The licensee was ir. formed that whenever a commitment date cannot be met, written notification should be submitted to the NRC indicating the problem encountered and specifying a new date when all corrective actions will be complet No dissenting comments were received from t'1e license The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspectio A telephone conversation between the inspector and a licensee representative was held on March 15, 1988, regarding the status of the

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evaluation of a hot p(article during the inspection exposure Paragraph 4.d.5). event reviewed by the inspector 3. Licensee Action on Previous Enforcement Matters (Closed) Violation 50-413/87-40-01, Failure to post a Notice of Violation as require The licensee's response dated January 8, 1988, was considered acceptable by Region II. The inspector verified that the corrective actions stated in the response had been implemente (0 pen) Violation 50-413/87-40-03, Failure to provide adequate procedures for controlling contaminated tool In a response to this violation dated January 8, 1988, the licensee indicated that certain specific changes would be made to the area where the contaminated tools were stored and that training of the individuals involved in handDng these tools would be completed by January 31, 1988. The inspector verified that the changes to the tool storage area had been completed as outlined. It was noted, however, that the training of the personnel involved had not been accomplished as of February 25, 198 The licensee indicated that- the new procedure controlling the operation of the tool room had just recently been reviewed and approved (February 23,1988) and that the training had been postponed pending this approva . Occupational Exposure During Extended Outages (83729) Audits and Surveillances l

The licensee is required by Technical Specification (TS) 6.5.2 to !

perform an anr.ual audit of the site radiation protection progra The inspector reviewed the annual audit performed by the Corporate office for 1987 and selected surveillances performed by site Quality Assurance (QA) personnel. The annual audit appeared to cover all )

aspects of the radiation protection program and be of adequate depth and performed by personnel with appropriate technical background The site QA surveillances were more limited in scope concentrating on one or two aspects of the program. The licensee indicated that the site surveillance program, with respect to health physics, was designed to be responsive to any currently identified problems or weaknesses in the health physics are i No violations or deviations were identifie !

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3 Planning and Preparation The present HP organization, staffing levels and lines of authority as related to outage radiation protection activities were discussed with licensee representatives. The organizational responsibility and control of the contractor HP technicians used during the outage were also discussed. After training had been completed and verified, contractor HP technicians were integrated into the licensee's work force and were assigned jobs commensurate with their experience and qualification A total of 144 contractor technicians and supervisors were recruited for the outag Involvement of the HP organization in the outage began in the early planning stages. HP technicians from the ALARA section were each assigned to follow the planning and preparation for each major outage evolution including removal of upper head injection (UHI) piping, resistance thermal detector (RTD) piping removal, sludge lancing and eddy current testing of steam generator The HP technicians, along with HP Supervisors, attended meetings held by the Integrated Scheduling Group (ISG). As the schedule developed, the technicians made suggestions to the ISG and had input related to dose rates, shielding and job coverage. The ISG was responsible for coordinating overall outage work to ensure that the outage flowed smoothl Control of contractor HP technicians and planning and preparation for the outage appeared to be adequate. Health Physics personnel were apparently involved early enough in the planning stages to allow for adequate job review and inpu No violations or deviations were identifie Training and Qualifications (83723)

Technical Specification 6.3 requires that members of the facility staff meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions. Paragraph 4.5.2 of ANSI N18.1 states that technicians in responsible positions are to have a minimum of 2 years of working experience in their specialt The inspector discussed the contractor technician training program with licensee representative Contract HP technicians were brought onsite prior to the outage in order to receive General Employee Training, site-specific training, respiratory protection training and on-tne-job training with in-house personne Licensee representatives indicated that contract technicians were hired based on an extensive review of resume It was the responsibility of one person in the HP group to screen all applicants and select those who had the proper credentials. Based on the

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resumes, individuals who met the ANSI N18.1 criteria were hired as senior technicians and placed in responsible position No violations or deviations were identifie External Occupational Exposure Control and Dosimetry (83724)

(1) Personnel Exposure Control The licensee is required by 10 CFR 20.101, 20.102, 20,201(b),

20.202, 20.401 and 20.407 to maintain workers' doses below specified levels and to keep records of the exposure One of the fundamental elements of the licensee's exposure control program is the Dose Card Syste Every time workers enter the Radiation Control Area, they are required to fill out a card indicating the individual's name and work group, Radiation Work Permit (RWP) number under which they will be working, allowed dose, remaining dose, time of entry and initial pocket chamber reading. When exiting, workers are required to enter the exit time and the final pocket chamber reading and dose for the entry. The same card is used to control internal exposures by tracking Maximum Pemissible Concentration-hours (MPC-hrs). At the end of the day, dose cards are collected and their information is entered into the compute A daily printout of updated exposure information is made available and workers are required to verify the accuracy of the information or point out discrepancies to health physics supervisio Problems with individuals failing to complete daily dose cards have been noted in the past. But, the inspector tracked his exposure during the course of the inspection and determined that ,

the system appeared to work as intended when the dose cards are I completed and turned in as require l The inspector reviewed the computer-generated summary of personnel exposures for individuals who received whole body exposures greater than 1.25 rems during the fourth quarter of 1987. The inspector also reviewed selected exposure records of personnel named in the summary and verified that a Form NRC-4 equivalent was properly filed before the individuals exceeded the 1.25 rem threshold. No individual had received exposures in excess of the 10 CFR 20.101(b) limit during the fourth quarter of 1987 or through February 25, 198 (2) Control of Radiation Areas 10 CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material ;

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During tours of the plant, the inspector reviawed the licensee's posting and control of radiation areas, hign radiation areas, airborne radioactivity areas, contamination areas, radioactive materials storage areas and the labeling of radioactive materials. The inspector performed independent radiation surveys throughout the facility using NRC equipment and verified that radiation fields measured were consistent with area posting (3) High Radiation Area Control Event The inspector reviewed Health Physics Report #87-35, dated November 4, 1987. On that date an individual entered Room 217, a posted high radiation area, without an integrating alarming dosimete Just prior to the entry the worker had told two health physics technicians that he had one. One of the i technicians informed a third HP technician, who was responsible i for issuing the alarming dosimeters, that the individual had entered Room 21 The third technician could not recall the individual requesting the integrating alarming dosimete- and

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confronted him. The individual indicated that he went into

Room 217 without technician Roomthe 217 dosimeter containedand a 4 admitted lying (to the HPR/hr) hot rem per hour spot, with a general area dose rate of 300 millirem per hour )

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(mR/hr) near the hot spot. The licensee took disciplinary I action against the individual by issuing a written reprimand and placing it in the person's personnel fil Technical Specification 6.12.1 requires that any individual permitted to enter a high radiation area, an area in which the i intensity of radiation is greater than 100 mR/hr but equal to or i less than 1,000 mR/hr at 18 inches from the radiation source, be l provided with or accompanied by a radiation monitoring device l which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is receive The inspector informed the licensee that failure of an individual to wear an alarming dosimeter into a high radiation area was apparent violation of Technical Specification 6.12.1. However, it was determined that the viciation met the criteria outlined in the NRC Enforcement Policy,10 CFR 2, Appendix C, and would be considered as a licenseeidentifiedviolation(50-413,414/88-12-01).

(4) Personnel Contamination Events During the Unit 1 outage there was a total of 136 contamination events, of which 30 occurred in the upper containment under RWPs that did not require protective clothin Licensee representatives pointed out that approximately 20,000 person-hours were spent during 14,000 entries into the

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upper containment on such RWP This represented less than a 0.4% contamination rate for all entrie (5) Hot Particle Exposure The inspector reviewed the Radiological Incident Investigation and Accountability (RIIA) Report No. 88-64 which documented the circumstances surrounding a hot particle exposure to the skin of the right knee of a worker. The worker entered the Unit 2 lower containment on February 1,1988, under RWP 88-689 to install eddy current testing cables. The worker indicated that he might have knelt down once or twice while performing his work. The individual worked approximately two hours and, upon exiting and frisking, contamination was found on his right knee. It was discovered that the contamination was a hot particle reading 17.3 mrad /hr (beta) and 0.9 mR/hr (gamma). The hot particle was imediately removed from the skin with tape and kept for analysi The licensee's initial investigation of this event resulted in a dose assessment of 6,433 mrem based on the reading of 1 mrad /hr from an RS0-5 ion chamber, an exposure time of 1.85 hours9.837963e-4 days <br />0.0236 hours <br />1.405423e-4 weeks <br />3.23425e-5 months <br /> and a correction factor (developed by the licensee)

of 201 for the instrument. The worker's quarterly skin dose prior to the incident was 740 mrem, therefore, the total dose assessment to the skin of the worker's knee was 7,143 mre The inspector discussed with licensee representatives the licensee's dose assessment methodology, specifically the determination of the correction factor for the R50-5 ion chambe Discussions regarding this issue included the effect of the difference between the size of the standard used for calibration at small distances and point sources, and the effect of gama radiation on the correction facto Licensee representatives agreed to evaluate the adequacy of their methodolog During a telephone conversation on March 15, 1988, between the inspector and a licensee representative, the inspector was informed that the individual's quarterly skin dose had been revised to 7,641 mrem. The revision was to account for 664 mrem of gama dose which had not been included and a small reduction in the beta dose assessment to 6,237 mrem deemed necessary after reevaluating their methodology. The inspector was informed that further evaluations of the effect of geometric differences between calibration and actual conditions were in progress and results would be available within a month. Any further revisions, if necessary, would then be mad Based on the licensee's assessment of the particle's activity of approximately 1.2 microcuries (uC1) of Cobalt-60 and an exposure

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time of 1.85 hours9.837963e-4 days <br />0.0236 hours <br />1.405423e-4 weeks <br />3.23425e-5 months <br />, the inspector determined that the skin dose would be 9,169 mrem using the methodology .in the computer code VARSKI Licensee representatives indicated that they were reluctant to use the VARSKIN methodology because it did not

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account for the self-absorption of beta radiation within the hot particles. They indicated- that ignoring self-absorption could result in overestimates as high as 30% in the beta dose assessment when using the VARSKIN methodolog Regarding regulatory compliance with the dose limits specified in 10 CFR 20.101, the inspector indicated that guidance provided in Information Notice 81-26, Part 3,. Supplement 1, Clarification of Placement of Personnel Monitoring Devices for External Radiation, dated July 19, 1982, considered the knee and below as extremities for radiation protection purpose Therefore, the dose limit for the skin of the knee would be that of the extremities,18.75 rem per quarter, and no dose in excess of regulatory requirements occurred in this inciden f No violations or deviations were identifie ; Internal Exposure Control and Assessment (83725)

10 CFR 20.103(c)(2) requires that, when respiratory protective equipment is used to limit the inhalation of airborne radioactive material, the licensee maintain and implement procedures regarding, among others, surveys and bicassays, selection and fitting of respirators, and training of personnel in the use of respiratory '

protective equipmen (1) Surveys and Bioassays The inspector reviewed RWP packages dealing with UHI piping work, decontamination of refueling canal, RTD piping modifications, steam generator sludge lancing and eddy current testing performed during the Unit 2 outage which was nearing completion at the time of tM inspection. The radiation level, surface contamination and airborne concentration surveys  ;

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included in the packages appeared to support the protective '

requirements specified in the RWPs reviewe The inspector reviewed investigations of whole body counts perfonned during the period November 1987 - February 1988. The

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inspector verified that the vast majority of the whole body 4 counts reviewed, which showed positive results, were due to low-level external contamination and not to uptakes of radioactive materials. The few measured uptakes reviewed reflected less than 5% of the maximum permissible organ burden (MP0B).

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(2) Respiratory Protection Training and Fitting of Respirators The inspector reviewed the licensee's respiratory protection training and the methods used for respirator selection and fit testin The classroom training consisted of approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of lecture, video tape presentation and practical factor demonstration. Topics covered included respirator selection, medical aspects of respirator use, proper fitting of respirators, maintenance of respirators, employee responsibilities and types of respirator Following the classroom presentation, a qualitative fit test was performed in a separate area as workers verified the adequacy of the seal in the presence of irritant smok After the training session, the inspector pointed out to training personnel that workers should be instructed to recognize symptoms of physical and/or mental stress associated with respirator use and to seek appropriate relief when such '

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symptoms were note Training personnel acknowledged the inspector's comments and indicated that they would ensure that such subject would be covered during respiratory training / retraining session No violations or deviations were identified, f. Control of Radioactive Materials and Contamination, Surveys and Monitoring (83726)

The licensee is required by 10 CFR 20.201(b) to perform surveys necessary to show compliance with regulatory limit The inspector observed several radioactive materials storage areas and verified that radioactive / contaminated materials were properly ,

stored and labeled. During tours of the plant, the inspector noted '

that housekeeping was not as good as it had been during the previous outage inspectio The inspector discussed with licensee representatives the uses and limitations of the personnel single access point (SAP). They indicated that they were evaluating its adequacy in minimizing the potential of low level contamination leaving the radiation control are The inspector noted that there was no HP technician assigned to the area, especially during peak hours. The technician nearest to ,

the area was located one level above and must be reached by <

telephone. The tools / equipment frisking station was also located one 4 elevation above the exit. After observing licensee personnel exit i

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the radiation control area (RCA) through the SAP, the inspector noted that some individuals were confused about whether items frisked at l the tools / equipment frisking station must be frisked again at the !

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SA Some individuals frisked all items again which had been surveyed previously at the frisking station while others only frisked

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the container carrying the items that had been surveyed at the frisking statio Licensee representatives acknowledged the inspector's coments and agreed to evaluate equipment release practice The inspector discussed the adequacy of signs regarding personnel monitoring which were located throughout the plant with licensee personne The signs in the men's change room located next to friskers which were to be used for whole body monitoring indicated that the friskers were there for convenienc Licensee representatives had indicated that personnel-contamination surveys were required in the change rooms when personnel had been working in contaminated area When the inspector brought this apparent discrepancy to the licensee's attention, they indicated that they would evaluate the adequacy of the sign No violations or deviations were identified, Maintaining Exposures ALARA (83728)

10 CFR 20.1(c) states that licensees should make every reasonable effort to maintain radiation exposures as low as reasonably achievable (ALARA), 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 consideration The inspector reviewed portions of the licensee's program for maintaining occupational exposures ALARA, as they related to the recent outag Areas reviewed included past ALARA evaluations, estimated versus actual doses and primary system crud control as it relates to exposure reductio ,

(1) ALARA Evaluations The inspector reviewed the ALARA Post Outage Report of the 1987 )

Unit 1 End of Cycle-2 Refueling Outage and associated health physics critiques and ALARA Job Observation Report ,

Health Physics feedback regarding the outage was categorized in l four areas: impact items, success stories, lessons learned and !

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improvement item Logistics and equipment problems were evaluated and techniques that proved to be beneficial were documented for future reference. It was also stated in a report reviewed that, even though ALARA incentives were implemented, their full effect was not achieved. Additional encouragement from management was requested in the Health Physics critique in order to improve general recognition of ALARA activitie l

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(2) Estimated vs. Actual Collective Doses The total collective dose for the Unit 1 outage was approximately 313 person-rem which included approximately 38 person-rem received during unanticipated work. This compares favorably with the anticipated total dose of 323 person-re The two major exposure jobs for the outage were installation of steam generator nozzle dams and shot-peening of steam generator tube The total estimated dose for these jobs was 113 person-rem, with the actual dose being 98 person-rem. The dose savings were attributed to experience gained at another plant, mock-up training, and constant pre-planning and communications between work group In addition, the extensive use of shielding reduced other general area dose rates by a factor of At the time of the inspection the Unit 2 outage was nearing '

completion. Licensee representatives indicated that the biggest ,

jobs of the outage had been the upper head injection work, resistance temperature detector removal and pressurizer heater repair. The goal for the outage was 277 person-rem. At the time of the inspection, the licensee had spent approximately 268 person-re Health physics personnel were working on documenting lessons learned and action items associated with that outag Licensee representatives indicated that the total estimated l collective dose for the site during 1988 is 552 person-rem, which includes 30 person-rem for unexpected / forced outage (3) Crud Control j i

Licensee reprer.entatives indicated that under routine operations the concentration of suspended solids in the primary coolant is in the order of 10 parts per billion (ppb). On a few occasions they had experienced crud bursts in concentrations of approximately 250 ppb. These concentrations are well below the manufacturer's maximum recommended concentration of 1,000 pp The licensee was evaluating the effect on radiation levels of pH changes and hydrogen peroxide addition to the primary coolant during the shutdown phase. Preliminary results indicated that pH changes have a greater effect on the release of deposited radioactivity which is insoluble at normal power then does the addition of hydrogen peroxid Licensee representatives .

indicated that short tenn results of these means of crud control I are limited to lowering the potential for surface contamination l since no measurable reduction in general area radiation levels !

had been observed. They pointed out that long-term effects would be significant in that the slower buildup of radioactivity

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in plant systems would. keep radiation levels lower over the life of the plan No violations or deviations were identified, h. IE Information Notices The inspector determined that the following Information Notice had been received by the licensee, reviewed for ' applicability, distributed to appropriate personnel and that action, as appropriate, was taken or schedule IN 87-39: Control of ' Hot Particle Contamination at Nuclear Power Plants

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