IR 05000413/1989011
| ML20245A881 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/18/1989 |
| From: | Potter J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20245A875 | List: |
| References | |
| 50-413-89-11, 50-414-89-11, NUDOCS 8906220237 | |
| Download: ML20245A881 (10) | |
Text
UNITED STATES -
- [.gi Karpk.
- NUCLEAR REGULATORY COMMISSION f-
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REGION li
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,j 101 MARIETTA STREET,N.W.
't ATLANTA, GEORGt A 30323
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JUN06He9 a
Report Nos.: 50-413/89-11 and'50-414/89-11 Licensee: Duke Power Company
422 South Church Street Charlotte, NC 28242
' Docket Nos.:. 50-413 and 50-414 License Nos.: NPF-35 and NPF-52 Facility Name: Catawba 1 and 2 Inspection Conducted: A,ril 17-21,1989 Inspector:
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F. N. Wright J.
Da{e f ne.
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Approved by:-
/U9 J. P. PQ Ker, Chief
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Fecilities Radiation Protection Section
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Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope This routine, announced inspection was conducted to evaluate radiation protection activities during extended outages.
The review included:
licensee organization and management controls; maintaining occupational exposures as low as reasonably achievable (ALARA); training and qualifications; control of radioactive material and surveys; internal and external exposure control; and licensee action on previously identified inspection findings.
Results-No violations or deviations were identified.
The inspection was conducted during the completion of Unit 2's refuel cycle. The licensee was in day 45 of the 60 day outage and was approximately six days behind schedule when the inspection began.
The inspector reviewed the status of five open items and was able to close three notice of violations (NOVs) and an inspector follow-up item (IFI). The fifth item concerned a violation issued for failure to take adequate and timely corrective actions for radiological ^ protect.,on violations.. At the time of the-inspection, the licensee disagreed with one of the examples. utilized in the corrective action violation.
Licensee representatives agreed to' respond to the violation by May 21, 1989 as an extension to the time earlier agreed upon.
8906220237 B90606
PDR ADOCK 05000413 G
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One new IFI was opened concerning the licensee's method for controlling l
calibrated pressure gauges utilized with supplied air respirators to ensure
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that sufficient flow could be maintained.
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REPORT DETAILS i
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Persons Contacted
i Licensee Employees W. Bradley, Manager, Quality Assurance Verification
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- W. Deal, Station Health Physicist
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A. Duckworth, Director, Technica' Services Training I
- J. Forbes, Manager, Technical Services
- V. King, Compliance Engineer J
- T. Owens, Station Manager j
Other licensee employees contacted during this inspection included technicians and office personnel.
i Nuclear Regulatory Commission i
- M. Lesser, Resident Inspector I
- W. Orders, Senior Resident Inspector l
- J. Potter, Section Chief, Division of Radiation Safety and Safeguards I
- M. Shymlock, Section Chief. Division of Reactor Projects
- Attended exit interview 2.
Organization and Management Controls a.
Organization The inspector reviewed the licensee's organization, staffing level and lines of authority as they related to radiation protection, radioactive material control, and verified that the licensee had not made organizational changes which would adversely affect the ability to control radiation exposure or radioactive material.
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Radiological Protection Corrective Action (1) Previous Violations In Inspection Report (IR) Nos. 50-413, 414/89-02, a violation was written concerning the licensee's failure to implement an effective corrective action program for radiological protection program violations.
In the March 3, 1989 letter transmitting IR No. 50-413/89-02, the NRC requested that the licensee be prepared to discuss timely and effective corrective acticns for the violation following a scheduled management conference in Region II on March 9,1989.
As a result of time constraints, the subject was not discussed with the licensee on that day.
The licensee responded, in their letter of March 31, 1989, to
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another violation issued in the same. report..The licensee stated that the. remaining corrective action would be further j
discussed with F. Wright of.the NRC in an announced inspection in April 1989.
In the exit meeting, licensee representatives reported that they disagreed with; portions of the 89-02-01 violation.as written.
Licensee representatives stated that the NRC was incorrect in the 50-413, 414/88-27 report which stated that the licensee had failed to complete corrective action for violation 87-31-02 by
. July 1988.
Licensee representatives agreed to provide a -
response to the NRC.concerning their position on the.89-02-01 violation by May 21, 1989.
(2) Recent Corrective Actions
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During the inspection, the inspector discussed additional examples of. inadequate corrective action within the previous =two-years.
(a) IR Nos. 50-413, 414/88-12 documented licensee failure to take timely corrective action for violation 50-413/87-40-03.
The violation was. written for failure to establish written procedures to assure that tools located'
in the hot tool room were stored with working levels of surface contamination less than 1,000.dpm/cm2 In 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 handling 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, 1988.
-The licensee. indicated that the new procedure control. ling the operation of the tool room ~ had just recently 'oeen reviewed and approved (February 23, 1988) and that the training hed been, postponed pending this approval.
(b)
IR Nos. 50-413, 414/88-27, documented te examples -of.
similar violations made within a 42. day. period in which licensee's initial corrective action was insufficient to -
t prevent recurrence. On June-4, 1988, two nuclear e operators (NE0s) violated radiological. protection 'quipment program requirements in an attempt to stop a leaking valve. Later, both of.~the NEOs were found to be contaminated with low levels of - radioactive material.
Following this incident, each of the supervisors of the NE0s involved was requested
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to review the event' and submit'their corrective actions to prevent recurrence.
As. of-the date of the 50-413, 414/88-27 inspection, no responses had been received by the Station Health-Physicist and no ~ corrective actions ~
implemented.
When the inspector asked about' a program or i
method to. follow up on : and ensure that responses were received in a timely manner from supervisors of individuals
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involved.in -radiological incidents, the licensee acknowledged this as a weakness in the Incident Investigation and Accountability program and initiated steps j
to provide for the specific follow-up information.
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On ~ July 15. 1988, two NE.Os again. violated radiological l
protection requirements when attempting to isolate a leaking valve without notifying the health physics (HP)
staff.
Again, the two NEOs were found to be contaminated with low levels of radioactive material.
Following this.
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I incident, the supervisor of the. individuals involved was
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requested to submit a written response to the station Health Physicist' detailing corrective actions to be taken to prevent recurrence of such.an event. Again at the time of the inspection, corrective action had not been I
addressed.
3.
General Employee Training (GET) (83723)
10 CFR 19.12 requires the licensee to instruct a_11: individuals-working in or frequenting any portion of the restricted area' in the health protection problems associated with exposure to radioactive material or radiation; in l
precautions 'or procedures to minimize exposures; and in the purpose and functions of protective devices employed, applicable provisions of Commission regulations, individual responsibilities and the availability of radiation exposure data.
The inspector reviewed the licensee's corrective action for violation 89-02-02, issued when two employees inadvertently entered a high
radiation area without crossing a barricade. The licensee was utilizing a yellow warning light' on a steam generator platform and the two workers did not know the significance of the warning lights.
The licenseewas utilizing the warning lights in high radiation ' areas where it was impractical to erect physical barriers.
A review of the licensee's GET, which is conoscted at'another licensee station, showed that the employees
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had not received any training on the use of yellow warning lights since I
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their permanent work station doe's not utilize yellow warning lights.
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result of the violation, the licensee's: corporate staff s'eviewed all station radiological protection. training programs and revised them. as neces'sary to ensure all utility radiation workers received instructions on the use of yellow warning lights regardless of assigned duty station.
No additional violations or deviations were identified, l
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4.
Internal and External Exposure Control (83724, 83725)
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10 CFR 20.103(b) requires the licensee to use process or other engineering controls, to the extent practicable, to limit concentrations of l
radioactive material in air to levels below that specified in Part 20, Appendix B, Table I, Column 1, or limit concentrations, when averaged over I
the number of hours in any week during which individuals are in the area to less than 25 percent (%) of the specified concentration.
The use of process and engineering controls to limit airborne radioactivity concentrations in the plant was discussed with licensee representatives and the use of such controls was observed during tours of the plant.
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l While touring Unit 2 upper containment, the inspector observed the use of supplied air hood respirators.
Appendix A of 10 CFR 20 allows the use of l
supplied air respirators to limit the exposure of airborne radioactive material provided the respirators are used and maintained under supervision in a well-planned respiratory protection program.
Footnote h of Appendix A allows the use of protection factors for tested and l
certified hoods when the air flow is maintained at the manufacturer's l
recommended maximum rate for the equipment and calibrated airline pressure j
gauges or flow measuring devices are used. The inspector determined that a licensee supplied air manifold, located in upper containment, did not have a calibration sticker or a unique method to identify and verify that the pressure cauge was properly calibrated.
The manifold was not being used when found.
The inspector asked licensee representatives to demonstrate that the pressure gauge had been calibrated or response checked.
The licensee only had six of the manifcids and the other five were uniquely identified with an etched serial number.
The inspector reviewed the pressure gauge certification sheets required by li(insee procedures and determined that the remaining manifold pressure gauge on the refuel floor bad been response checked to a National Bureau of Standards (NBS) traceable calibrated pressure gauge December 28, 1988.
The licensee reported that the manifold box had been contaminated and decontaminated with a sand blaster which had removed the etched serial number.
The licensee reported that the manifold boxes would be stamped with a serial number in the future. The inspector stated that a review of the licensee's accountability of breathing air manifolds and response checked pressure gauges would be reviewed in the future as an inspector follow-up item (IFI) 50-413/89-11-01.
10 CFR 20.202 reauires each licensee to supply appropriate personnel monitoring equipment to specific individuals and require the use of such equipment.
During tours of the plant, the inspector observed workers wearing appropriate personnel monitoring devices.
10 CFR 20.203 specifies the posting, labeling, and contrM requirements for radiation areas, high radiation areas, airborne radioactivity areas, and radioactive materia }
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During ' tours of the plant, the inspector reviewed the licensee's posting and control and rauiation areas, high radiation areas, and the labeling of a
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radioactive material.
The inspector made independent surveys and determined that the areas reviewed were properly posted.
The inspector reviewed selected active radiation work permits (RWPs) for I
appropriateness of the radiation protection requirements based on work I
scope, location, and conditions. During tours of the plant, the inspector j
observed the adherence of plant workers to the RWP requirements and discussed the RWP requirements with plant workers at the job site.
10 CFR 19.11 requires that each licensee post current copies of 10 CFR 19-and 10 CFR 20 or, if posting of the documents is not practicable, the i
licensee may post a notice which iescribes the document and states where it may be examined.
10 CFR 19.11 further requires that copies of any Notice of Violation involving radiological working conditions be conspicuously posted within two werking days after receipt of the documents from the Commission.
The inspector observed the posting of notices requires by 10 CFR 19.11 during tours of the plant.
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No violations or deviations were identified.
5.
Surveys and Control of Radioactive Material (83726)
10 CFR 20,201(b) requires each licensee to make or cause to be made such I
surveys as (1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
The inspector discussed with the licensee the method used to release material from the restricted area and observed technicians performing release surveys for material.
No violations or deviations were identified.
6.
ALARA(83750)
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10 CFR 20.1(c) states that persons engaged in activities under licenses
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issued by the NRC should make every reasonable effort to maintain radiation exposure as low as reasonably achievable (ALARA).
The recommended elements af an ALARA program are contained in Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation
Exposure at Nuclear Power Stations will be ALARA," and Regulatory Guide 8.10. " Operating Philosophy for Maintaining Occupational Radiation Exposures ALARA."
The licensee had estimated a person-rem total of approximately 250 for the Unit 2 Cycle 2 refueling outage.
At the time of the inspection, the licensee had accumulated about 178 person-rem and the outage was behind
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schedule by approximately six to eight days.
The ALARA coordinator reported improvements in the plant staff's involvement in the ALARA
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program with specific positions included on the ALARA Committee.
The-licensee reported increased cooperation' between plant groups and better.
planning was resulting in ALARA program improvements.
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No violations or deviations were identified.
7.
Licensee Actions on Previously Identified. Inspection Findings (92701, 92702)
a.
(Closed) NOV 50-413/87-31-02:. This item concerned the failure' to adhere to radiological control procedures. for personnel contamination monitoring and completion of daily dose cards.
The inspector reviewed the results of the six-week appraisal in 1988.
In an effort to improve frisking and dose card compliance, the licensee had reduced the number of portals into. the main RCA. to three. During the inspection,.the licensee ha_d a station at the main'
RCA entrance which allowed HP personnel to monitor all three areas, one via television monitor and the other two directly. The licensee personnel _ assigned to the station verified that persons entering the.
area had completed a. dose card correctly and observed lpersonne11 monitoring with whole body friskers.
The' licensee-also had whole body friskers in the dressout areas.
The licensee had made improvements in both frisking and : dose ' card activi. ties.,
The inspector closed this item, b.
(Closed) NOV 50-413/88-27-01:.This item. concerned failure to adhere to radiological controls for. entry into radiation'.and radioactive contaminated areas.
The inspector _ reviewed licensee records and determined that the shift supervisors had discussed the.need to.
comply with radiological control procedures. Through interviews with'
licensee representatives, the inspector determined that.the licensee had discussed the need to follow radiological control procedures with operations personnel in routine safety meetings.. The inspector closed the item.
c.
(Closed) NOV 50-413/89-02-02: 'This item concerned failure to provide GET for _ employees concerning the significance of flashing yellow lights used in high radiation areas.- Two licensee employees assigned to another licensed station inadvertently entered a high radiation area having a warning light on a steam generator. platform.
The two men who entered the area from above had not. received any training on t"a use of warning lights at their. home station.
The inspector.
_ mined that the employees' home station did :not utilize' the wm ntng lights. -
The ' licensee revised, as needed, all' general'
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employee training programs at each station to include information'on the use of warning lights.
The inspector closed this item.
d.
(Closed) IFI 50-413/87-31-01:
This item concerned the' licensee's procedure for Determining dose to the skin from hot particles. The inspector reviewed the licensee's ' procedure -HP/0/B/1009/02,
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" Investigation of.Possible Overexposure, Personnel Contamination, and/or Unusual Radiological Occurrences," dated April 7, 1989..
Attachment A of the procedure provided the method for determining skin dose to hot particles.
The inspector stated that a technical review of the procedure would be made in the Regional office.
The Region staff determined that the licensee's. method for evaluating dose to the skin from a hot particle was an acceptable method. The inspector closed th s item from the Regional office.
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Exit Interview
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Inspector Coninents l
The inspection scope and findings were summarized on April 21, 1989,
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with those persons indicated in Paragraph 1 above.
The inspector reported to management that the persons interviewed were positive and cooperative, b.
.New Items
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The inspector determined that. the licensee had calibrated pressure gauges on portable breathing air manifolds; however, the inspector discovered that at least one manifold was not uniquely identified to verify calibration status.
The manifold assembly had been deconned with a sand blaster and the etched serial number was removed..The licensee planned to stamp the serial number on the case.
The inspector stated that a review of the licensee's accountability of l
breathing air manifolds and response checked pressure gauges would be reviewed in a future inspection as an inspector follow-up item-(IFI50-413/89-11-01).
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Previously Identified Inspection Findings The inspector discussed the status of previously identified items discussed in paragraph six with licensee management and reported the
following:
(1) NOV 50-413/87-31-02:
This' item concerned. failure to adhere to'
radiological control procedures ' for personnel contamination l
monitoring and completion of daily dose cards.
The. inspector determined through a review of licensee records and interviews with licensee ' employees that' a special evaluation of frisking
and dose card errors had been documented in 1988, and' that
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management was continuing to monitor these activities informally. The inspector closed the item.
,j (2) NOV 50-413/88-27-01:
This item concerned failure to adhere to radiological controls for entry into radiation and radioactive contaminated areas. The inspector reviewed licensee records and
. determined that the shift supervisors had discussed the need to comply with radiological control procedures. Through interviews
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- 8 with licensee representatives, the inspector. determined that.the licensee had. discussed the need to follow radiological control procedures with operations personnel in routine. safety meetings.
The inspector closed the item.
(3) NOV 50-413/89-02-02:
This ~ item concerned failure to provide general employee training for. employees-concerning.the significance of flashing yellow lights used 'in. high radiation areas.
The inspector determined that the employees' home.
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station did not utilize ~ the warning lights.
The licensee revised, as needed, all ' general employee training programs at each station ~ to include information on. the use of warning lights. The inspector closed the item.
.(4) 1FI-50-413/87-31-01:
.This item concerned the licensee's-pr.ocedure. for determining dose.to the' skin from hot particles.
The inspector reviewed-the_ licensee's procedure HP/0/B/1009/02,
" Investigation of Possible Overexposure, Personne1'
Contamination, and/or Unusual -Radiological: Occurrences," dated
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April 7,1989.
The inspector stated that a technical review ^of the procedure would be made -in the. Regional Office.
The Regional staff ~ determined that the licensee's! method 'for evaluating dose to the skin from: a hot particle was an.
acceptable method.
The inspector closed this' item.from: the~
Regional Office.
The inspector discussed the' basis for previous violation 50-413/89-02-01'
with the plant manager, as outlined in.Section 2.b, above. ' Licensee representatives reported that: they ' disagreed - with portions' of the
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violation as written.
Licensee representatives agreed to' respond to the violation by May 21, 1989, as an extension' to the time earlier agreed upon.
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