IR 05000413/1988027
| ML20207J812 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/09/1988 |
| From: | Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207J799 | List: |
| References | |
| 50-413-88-27, 50-414-88-27, NUDOCS 8809280130 | |
| Download: ML20207J812 (12) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION d
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0 101 M ARIETT A STREET, N W.
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up16ra Report Nos.: 50-413/88-27 and 50-414/88-27 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 282',2 Docket Nos.:
50-413 and 50-414 License Nos.: NPF-35 and NPF-52 Facility Name:
Catawba 1 and 2 Inspection Conducted: July 19-22, 1988 Inspector:
bbMIh f/M8 C. H. Bassett Vate' Signed Approved by:
i NWT h !'l C. M. Hose /.'Section (hief Date Si'gned'
Division of RadiationlSafety and Safeguards SUMMARY Scone:
This routine, unannounced inspection was conducted in the area of Iadiation protection including:
organization and management controls; the solid waste program; transportation and licensee action on previous inspection findings.
Results:
One violation was identified involving an apparent failure of operations persennel to follow radiological control procedures on two occasicns during respontes to stop leaks in radioactive systems (,oaragraph 2.J.).
During the inspection, 'te licensee's failure to take full corrective actions in response to a previously identified violation was noted (Paragraph 5). This was a second example of the licensee's failure to take full corrective action.
The first such exarple was noted during an inspection conducted on February 22-26, 1988.
Other aspects of the licensee's radiation protection program were assessed to be adequate in the areas covered during the inspection.
8809280130 800916 PDR ADOCK 05000413 O
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t REPORT DETAILS 1.
Persons Contacted Licensee Employees
- H. Barron, Superintendent, Operations
"T. Crawford, Superintendent, Integrated Scheduling
- M. Cote Compliance Specialist C. Couch, Supervisor, Dose Records Control
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- W. Deal, Station Health Physicist P. Grayson, Relief Supervisor, Chemistry
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D. Hickey. Health Physics Specialist
- T. Holland, Shift Engineer. Integrated Scheduling
- D. Miller Quality Assurance Specialist
- W. Miller, Planning Engineer G. Mode, General Support Supervisor, Health Physics
- T. Owen, Station Manager, Catawba Nuclear Station (CNS)
5. Rcdgers, Shift General Supervisor, Chemistry
- R. Wardell, Superintendent. Technical Services Other licensee employees contacted during this inspection included engineers, operators, technicians, and administr uive personnel.
Nuclear Regulatory Comission
- M. Lesser, Resident inspector
- Attended exit interview Acronyms and initialisms used throughout this report are listed in Paragraph 7 of this report.
2.
OrganizationAndManagementControl(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 responsibilities, authority and other management controls necessary for establishing and maintaining a health physics (HP)
program for the f acility are outlined in Chapters 12 and 13 of the Final Safety Analysis Report (FSAR).
The inspector reviewed the licensee's plant organizaticn, as well as the responsibilities, authority and control given to management as they relate to the site radiation protection program.
Recent changes in plant management were reviewed and it was verified that no organizational changes had been made which would adversely affect the
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4 ability of the licensee to continue implementing the critical elements of the program.
The inspector discussed the support received for the radiation protection program with the Station Health Physicist and determined that it was adequate and improving, b.
Staffing TS 6.2.2 outlines the minumum staffing for the facility.
FSAR Chapters 12 and 13 provide further details on staffing levels at Catawba Nuclear Station (CNS).
The inspector reviewed the staffing level of the station health physics organization with licensee representatives.
At the time of the inspection all 103 authorized health physica positions at the facility were filled.
Of the 70 authorized technical positions at the station, 64 were occupied by technicians / specialists who were qualified to the req (uirements outlined by the American National Standards Institute ANSI) Standard N18.1-1971.
Three contract technicians were also employed to assist in the As low As Reasonably Achievable (ALARA) Section and in the Radioactive Materials Control (RMC) Section.
c.
Controls The inspector reviewed t se licensee's program for identifying and correcting radiological and safety related problems at the station.
The main tools used for this purpose were the Health Physics Problem Reports and the Radiological Incident Investigation and Account-ability (RII A) Reports.
All the HP Problem Reports reviewed dealt with the failure of personnel to leave their dosimeters in the proper location for processing by the Dosimetry Section and the actions taken to enrrect the recurrent problem.
The RIIA Reports were used primarily to document personnel contaminations, however, other problems were reported as well.
d.
Personnel Contamination Reports TS 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 radiatien exposure.
Catawba Nuclear Station Directive 3.8.8, Radiological Work Practices, Revision 18. dated June 6,1988, requires in Section 2.1 that all employees exercise good radiological work practices including reading and complying (with posted Radiation Work Permits / Standing Radiation Work Permits RWP/SRWP) pertaining to the Radiation Control Zone (RCZ) of interest, contacting the Surveillance and Control (S&C)
Section of Health Physics for needed job coverage and cooperating fully with Health Physics personnel in all matters pertaining to radiation protection, m
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Catawba Nuclear Station Directi"e 3.3.3, Contamination Prevention, Control and Decontamination Responsibilities, Revision 22 dated January 21, 1988, requires in Section 5.1.1.8 that any person needing to contain a leak should contact the Health Physics group for assistance.
Through discussions with licensee representatives and reviews of RIIA Reports, the following problems were noted.
(1) During the evening of June 4,1988. Control Room personnel noticed instrumentation indications of a leak in the Spent Fuel Pool Cooling (KF) system.
HP was notified of the problem and four haclear Equipment Operators (NEOs) were dispatched to the 577 foot elevation of the Auxiliary Building where a valve was found to be leaking.
Two of the operators working under the constaints of SRP? 88-2 proceeded to stop the leak by attempting to repair the valve in place without waiting for surveys, job coverage or evaluation by HP.
The valve was partially repaired and the leak rate reduced frcm approximately 50 gallons per minute (gpm) to about 2 gpm.
When the HP technicians arrived, the two NEOs, who had been involved with repairing the leaking valve and consequently sprayed by the KF water, were surveyed with portable friskers.
No contamination levels greater than 150 corrected counts per minute (ccpm) were detected at that time, They were released and allcwed to return to the Control Roem.
However, when ont HE0 performed a personnel contamination survey at the exit to the Radiation Control Area (RCA) using the hand and foot monitors as required, the monitors alarmed indicating the presence of contamination.
Another survey performed at the exit by HP technicians using friskers indicated that no contamination above 150 ccpm was present tut the hand and foot monitor still alarmed when the right shoe was placed on the detector.
The shoe, which was reading about 90 ccpm, was decontaminated and the operator released at that time.
Later that evening, however HP requested that the NEO return the clothing he had been wearing and found his T-shir t, shirt and pants were contaminated as well with activity ranging from 0.2 to 0.5 nanocuries of Cobalt-58 and Cobalt-60, Cesium-134 and Cesium-137, Antimony-125.
The hand and foot monitor also alarmed as the other NE0 attempted to exit the RCA.
Both of the other NE0's shoes were found to be contaminated to a level of approximately 90-100 cenn with the same isotcpes found on the other person's clothing plus Fluorine-18. Her socks, however, which were wet from the incident, were not contaminated.
Although contamination was found on both operators' shoes and on one operator's clothing, none was found en their skin.
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Particulate and gaseous air samples taken in the area where the
valve was leaking showed indications of tritium airborne l
radioactivity present at a concentration of 2.35 E-8 uCi/ml. A
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liquid sample analyzed for tritium also showed positive sosults j
of 4.6 E-2 uti/ml.
Because of the liquid and gaesous sample
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results and the fact that both individuals had been sprayed by
KF water, each was given a whole body count (WBC) and requested
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to submit a urine sample. The WBC results indicated no internal
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deposition of activity while the urinalysis indicated net
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positive results of 7.74 E-3 uti/l for one individual and 6.69 E-3 uCi/1 for the other.
These urine concentrations were
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below the licensee's action level of 10% of their maximum l
permissible urine concentration of 5.09 E-1 uC1/1, The licensee i
calculstad that the Tritium intake for the individuals was i
w roximately 0.24 Maximum Pemissible Concentration-hours
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(NPC-hrs).
r Following this incident, each of the supervisors of the NEOs
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involved was requested to review the event and submit their
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corrective actions to prevent recurrence.
As of the date of the inspection, no responses had been received by the Station Health
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Physicist and no corrective actions implemented.
When asked
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about a program or method to followup on and ensure that
responses were received in a timely manner from supervisors of l
individuals involved in radiological incidents, the licensee l
acknowledged this as a weakness in the RI!A prograi. and
initiated ster. to provide for such followup.
- Failure of licensee personnel to follow plant procedures
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requiring them to wait for HP to provide e eeded job cov.nrage for repair of the leak in the XF system was identified as an
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apparent violation of TS 6.11(50-413,414/88-27-01).
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'2) On the mrrning of July 15, 1988 Control Room personnel rioted
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instrumentation indications of a leak in the Volume Control Tank I
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system.
Two TEOs were told to locate the leak, which was I
apparently coming from a relief valve, and stop it because
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approximately 450 gallons of make-up water had to be added to
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the system in the last hour and one-half.
The two NEOs entered the RCS under toe constraints of SRWP 88-2, Routine Surveillance
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for Plant and System Operation (which required notification of
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HP prior to starting work) and proceeded to locate the leaking
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valve in Room 243 on the 543 fcot elevation of the Auxiliary Building.
The NEOs dressed in partial personal protective clothing (PCs) consisting of a total wet suit, shoe covers and gloves in one case and a disposable sack suit, paper hood, wet suit bottoms, shoe covers and gloves in the other case.
The NEOs attempted to isolate the leak without notifying HP and without any surveys or evaluation of the radiological conditions being perfomed.
After working for approximately 30 minutes, i
the NE0s were able to isolate the leak. During this time an HP
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technician, who was performing a pre-job survey in the area, noticed the NEOs and informed the HP office of the situation.
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An HP technician was sent to the area to take an air sample and assess the radiological conditions, but the two NEOs left the area shortly before the HP technician arrived. Upon performing
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a personal contamination survey before leaving the 543 foot elevation, bot' ind' iduals found that they had contamination on their heads so they..ent to the personnel change room to seek assistance from HP.
One individual was found to have contamination levels up to 1300 ccpm en his forehead and 1000 ccpm in his hair.
The individual's shirt aad pants were
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elso found to be contaminated with Cobalt-58 and Cobalt-CO, Cesium-138, Fluorine-18, lodine-132, Manganese-54 and
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Rubidium-88.
The other NEO had contamination levels up to
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1300 ccpm in her hair but no other contamination was detected.
Particulate and gaseous air samples were subsequently taken in the area where the valve had been leaking but no water sample was analyzed for the presence of tritium.
Airborne radioactivity levels of 1.03 times the Maximum Permissible Concentration (MPC) for particulate radionuclides specified in 10 CFR Part 20, Appendix B, Table 1. Colume 1 and gaseous levels
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at 12.2 times the MPC were identified.
A maximum of 0.52
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MPC-hours was assigned to each of the NEOs based on the time of exposure to particu'ite airborne activity and MPC for
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particulates.
A skin dose cf 0.47 millirem (mrem) was assigned
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to the Individual with skin contamination and a maximum skin i
dose of 3 mrem was assigned to each of the NEOs due to the radioactive gases.
The NEOs and the HP technician who took the air samples were
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given whole body counts but no urine samples were collected for
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i analysis, the WBC results indicated one individual had en
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uptake of approximately three percent (3%) of a Maximum Permissible Organ Burden (MPOB) to the lungs of Cobalt-58 and t
Surveys were also made of the areas where the NEOs had walked following work on the leaking valve.
The results of I
the contamination surveys of the areas through which the NEOs f
traveled following the incident indicated that no spread of
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contamination had occurred.
Following this incident, the supervisor of the individuals involved was requested to submit a written response to the Station Heulth Physici!
detailing the corrective actions to be taken to prevent recurrance of such an event. HP was continuing
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to investigate the incident at the time of the inspection and no corrective or other actions had been taken.
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l The inspector discussed with the licensee the apparent lack of
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sensitivity by operations personnel to HP controls and the
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apparent failure to follow procedures and the requirements of the RWP.
The adequacy nf followup actions by HP and the lack of supervisory response to correct the problems were also discussed.
The licensee indicated that the apparent lack of sensitivity to HP controls was due to the fact that the operators had perceived these situations as emergencies and had proceeded to correct the problems causing the emergency.
The licensee was informed that this and the previously mentioned situation did not qualify as emergenc M.
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Failure of the NEOs to follow plant procedures requiring notification of HP and adherence to RWP requirel '"ts was identified as a second example of an apparent violation of TS 6.11 (50-413, 414/88-27-01).
3.
SolidWaste(84722)
a.
Waste Classification and Characterization 10 CFR 20.311(d)(1) requires that licensees prepare al', waste such that the waste is classified in accordance with 10 CFR 61.55 and meet the waste characteristic requirements specified in 10 CFR 61.56.
The licensee is currently sarpling five waste streams annually:
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active waste (DAW) and waste oil, resin including powder and bead l
resin, filter media, evaporator concentrates and reactor coolant.
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l The samples are sent to a vendor for analysis and the results are
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l The GO then develops the site-specific scaling factors for use by the RMC Section of HP. A selective review of the sampling results by the
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inspector indicated that there had been no significant variation in r
the relative cencentrations of the samples and that the scaling factors appeared to be appropriate.
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The licensee uses a vendor-supplied computer program (WASTETRAK)
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which processes input survey information obtained from a package of waste together with the scaling factors to deterriine the proper L
classificatun and transportation type. The licensee indicated that
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procedures are in place wht:h can be used as a backup to the computer program and are used, on occasion, to verify the computer-generated results.
The inspector reviewed the licensee's procedures for waste classification and verified that they were adequate, f
The inspector discussed the program for waste stabilization with the
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licensee representatives.
The licensee has only used the Process Control Program for solidification once to date which entailed t
t solidifying sediments from the floor drain tanks.
The typical waste precessing activity in use is dewatering resins and this is performed j
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by the Chemistry group using vendor-supplicd procedures. The resins are placed in approved containers to provide for stability and to meet burial site requirements.
The inspector reviewed CNS Operations Procedures OP/0/B/6500/09, Operating Procedure for the Control and Use of Vendor Procedures, Revision 2 dated April 28, 1988, which incorporates the vendor's procedures into the CNS system and provides approval for their use, b.
Waste Manifests i
10 CFR 20.311(b) requires tL>t each shipment of radioactive waste to a licensed isnd disposal facility be accompanied by a shipment manifest and specifies required entries to be made on each manifest.
The inspector reviewed selected records of radioactive waste
shipments performed during 1988 and verified that the manifests had been completed properly.
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Waste Segregation Program The inspector reviewed the licensee's program for segregating waste.
On all elevations throughout the RCA of the facility the licensee has placed waste receptacles (barrels) for clean and contaminated waste.
Each barrel is given an individual number and the location of each barrel, along with the number, is maintained on a log kept in the HP office.
(l.aundry barrels are also numbered and their location tracked, when applicable, such as during outages or when other radiological work is being performed.)
When the janitorial vendor gathers the liners from each of these receptacles, the number is written on the bag and they are surveyed for radiation and
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contamination.
The bags are then taken to a central location for l
processing, in this manner, the licensee can determine where problems are occurring, and possibly from what jobs, should
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contamir:*ed waste appear in a clean bag.
The clean bags are monitored by HP technicians before being released
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I and taken to the site ccmpactor and eventually off-site with all the other clean waste.
The licensee is currently evaluating the acceptability of a vendor-supplied bag monitor. The bag monitor has two large sodium iodide detectors which can reportedly detect levels down to 250 dpm/100 cm2.
i The contaminated waste bags are taken to an area where the initial
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millirem per hour (mr/hr)s with radiation levels in excess of 100 segregation occurs.
Bao are not opened for waste segregation due to the high radiation levels present.
Other bags are taken to an area where the licensee has set up a vender-supplied waste sorting system, The bags are opened on a table which has a hood with negative i
ventilation over the top and one inch by twelve inch rections of
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plastic sheet hanging down to aid in containing any contamination that may be present.
The items in the bags are then spread on the l
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I table and surveyeo under large area (575 square centimeters) gas flow proportional detectors.
These detectors have a reported detection capability of 800 ripe /100 cm2 All contaminated items are placed in j
another bag while the cican waste is placed on a conveyor belt which leads to a shredder and compactor. Before being compacted the waste
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again passes through a series of detectors with a reported detection limit of 325 dpm/100 cm.
The bags of contaminated waste are then r
placed in large shipping containers, along with the bags which read greater than 100 mr/hr, and shipped to a vendor for super-compaction.
d.
Radwaste Shipments Through discussions with licensee representatives and review of licensee documents, it was noted that 9623 cubic feet (f t8) of solid radioactive waste containing 279 curies of activity had been shipped from the facility during 1987.
Through June 30, 1988, the licensee had made 19 waste shipments consisting of 12,378 ft3 of waste containing 391 curies of activity.
Also, a total of 1723 f t3 of waste remained in storage awaiting shipment.
It was also verified that a system was in place to maintain copies of the manifests and the receipt verification received frem the consignees.
No violations or deviations were identified.
Transportation (86721)
10 CFR 71.5 requires that licensees who transport licensed material outside the confines of its plant to other place of use, or who deliver licensed material to a carrier for transport, shall comply with the applicabl? requirements of the regulations appropriate to the mode of transgort of the Department of Transportation (00T) in 49 CFR Parts 170 through 189.
The inspector reviewed selected records of radioactive waste and radioactive material shipments performed during 1988.
The shipping manifests examined were prepared consistent with the 49 CFR requirements.
The radiation and contamination survey results were within the limits specified for the mode of transport and shipment classification and the shipping documents were being ccmpleted and maintained as required.
No violations or deviations were identified.
5.
1.icense Action On Previous Inspection Findings (92701, 92702)
(0 pen)IFI 413,414/87-31-01, Followup en Procedure Revision A previous inspection identified the need to revise the licensee's procedure describing skin dose calculations due to hot particles.
Although the licensee has been working on the project, the procedure revision has yet to be completed.
The licensee indicated that the
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revision was scheduled to be completed by the end of July for review and approval.
(0 pen) Violation 413, 414/87-31-02, Failure to Adhere to Radiological Control Procedures for Personnel Contamination Monitoring and Completion of Daily Dose Cards.
During a previous inspection it had been noted that personnel were not performing adequate personal surveys upon exiting the RCA and were not completing daily exposure cards as required.
The inspector reviewed the licensee's response dated November 17, 1987, and the supplemental response dated December 11, 1987, and cetermined that the licensee had established a Single Point Access (SPA) as had been indicated.
The inspector also reviewed the CNS Directive that had been revised as a result and various HP signs and documents.
An HP SPA log book was also reviewed which documented implementation of a program of routine observations at the SPA to monitor dosimetry, dose card completion and frisking.
The licensee's response also indicated that an imediate program of routine observations would be irrplemented to improve overall management involvement in assuring compliance with the frisking and dose card requirements.
The licensee stated that they would be in full compliance on March 1,1988.
However, as of the date of the inspection, the program of routine observations had not been implemented.
The inspector noted that this was the second time in as many inspections that the licensee had failed to meet all aspects of their cornitments to the NRC by the date established by the licensee.
(Closed) Violation 413, 414/87-40-03, Failure to Provide Adequate Written Procedure for Controlling Contaminated Tools During a previous inspection, contaminated tools had been found in a non-contaminated areas of the Hot Tool Room with levels of contamination in excess of the established limits.
On a subsequent inspection, it was noted that the licensee had not completed all the corrective actions indicated in their response dated January 8,1988.
The licensee had agreed to train personnel following revisions to the tool handling procedure and reorganization of the Hot Tool Room.
The training had not been given as of the last inspection.
During this inspection the inspector verified that the training had been completed.
6.
Exit interview The inspection scope and findings were sumarized on July 22, 1988, with those persons indicated in Paragraph 1, The inspector described the areas inspected and oiscussed in detail the inspection findingt.
The licensee i
did not identify as proprietary any of the material provided to or
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reviewed by the inspector during this inspection.
No dissenting coments
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were received frem the licensee.
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The item listed below was identified as an unresolved item during the exit interview.
However, following NRC management review, the licensee was notified on September 8,1988, via K. Van Doorn, NRC Senior Resident inspector at Catawba, that failure to follow radialogical control procedures would be considered a violation of TS 6.11.
Item Number Description and Reference 413,414/88-27-01 Violation - Failure to follow radiological control procedures requiring notification of HP and adherence to RWP requirements and/or HP job coverage during responses to stop leaks in radioactive systems.
Licensee manageuent was informed that one IFl and one violation discussed in Paragraph 5 will remain open and that one violation was considered closed.
7.
Acronyms and Abbreviations ALARA As low as Reasonably Achievable ANSI American National Standards Institute CNS Catawba Nuclear Station ccpm Corrected counts per ninute dpm/100 cm2 Disintegrations per minute per one hundred square centimeters DAW Dry Active Waste 00T Department of Transportation FSAR Final Safety Analysis Report ft3 Cubic feet G0 General Office gpm gallons per minute HP Health Physics KF fuel Pool Cooling System MPC Maximum Pemissible Concentration MPC-hr Maximum Pemissible Concentration-hour MP0B Maximum Pemissible Organ Burden mr Milliroentgen mr/hr Milliroentgen per hour NE0 Nuclear Equipment Operator PCs Personal Protective Clothing RCA Radiation Control Area RCZ Radiation Control Zone RilA Radiological Incident Investigation and Accountability Report RMC Radioactive Materials Control RWP Radiation Work Permit SRWP Standing Radiation Work Pemit
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S&C Surveillance and Control TS Technical Specification WBC Whole Body Count i
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