IR 05000413/1993029
| ML20059B860 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/12/1993 |
| From: | Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059B833 | List: |
| References | |
| 50-413-93-29, 50-414-93-29, NUDOCS 9401040269 | |
| Download: ML20059B860 (12) | |
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NUCLEAR REGULATORY COMMISSION UNITED STATES-y
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REGION 11
S 101 MARIETTA STREET, N.W., SUITE 2930
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g ATLANTA, GEORGIA 30323-0199 s%.....!
DEC 151983 Report Nos.:
50-413/93-29 and 50-414/93-29 Licensee: Duke. Power Company P. O. Bcx 1007 Charlotte, NC 28201-1007 Docket Nos.:
50-413 and 50-414 License Nos.:
NPF-35 and NPF-52 Facility Name: Catawba 1 and 2 Inspection Conducted: November 15-19, 1993 N.
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Inspector:
Date/Sidned~
R. B. Snortridge
Accompanying Perso nel:
W. Loo Approve y:
?W (W
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A. W.11. Rankfri, Chief Dat6 Sfgned Facilit4et Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, announced inspection was conducted in the area of occupational radiation safety and included an examination of:
organization and management controls, training and qualification, audits and appraisals, external exposure controls, control of radioactive materials and contamination, surveys and monitoring, and maintaining occupational' exposures ALARA. Also, followup on previously identified inspection items was accomplished.
Results:
Based on interviews with licensee management, supervision and personnel from station departments, and records review, the inspector found the radiation protection (RP) program to be effective in protecting the health and safety of plant employees. All work observed was performed using good radiological techniques and posting, labeling, and control of radioactive material was considered a strength as was control of contamination.
9401040269 931215 PDR ADOCK 05000413 G
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REPORT DETAILS l
1.
Persons Contacted
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Licensee Employees j
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- J. Coleman, Quality Control Supervision, Mechanical Maintenance (MM)
- S. Coy, Radiation Protection Manager
- W. Deal, Manager, Customer Support /GSD
- J. Forbes, Manager, Engineering
- R. Kaye, Steam Generator Station Sponsor, Corbustion Engineering
- W. Lilly, Instructor /GSD-
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- J. Lowery, Specialist, Regulatory Compliance
- W. McCollum, Jr., Station Manager
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- P. Pappas, Owner's Group
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- D. Rhen, Vice President, Catawba Nuclear Station
- G. Robinson, Quality Control, General Supervisor, MM
- Z. Taylor, Manager, Compliance
- J. Twiggs, Radiation Protection, General Supervisor l
Other licensee employees contacted during the inspection i
included technicians, maintenance personnel, and administrative
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personnel.
l Nuclear Regulatory Commission
- R. Freudenberger, Senior Resident Inspector
- Denotes attendance at exit meeting held on November 19, 1993 l
l 2.
Organization and Management Controls (83729)
The inspector reviewed changes made to the licensee's organization,
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staffing levels and lines of authority as they related to radiation I
protection (RP).
Since the last inspection, the licensee filled.the l
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vacancy for the RP Manager position. The inspector determined that the new appointee met the qualification requirements specified in the
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Technical Specification (TS). Also, it appears that the transition has
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been smooth as the licensee's RP program continues to operate efficiently and effectively. The new appointee is a certified health
physicist with good applied health physics experience.
Within the licensee's organization, three General Supervisors reported
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to the RP Manager, one of which has just been succeeded by a supervisor from Corporate RP and one General Supervisor position was eliminated.
In discussions with licensee management, the inspector learned that the licensees's RP staff had been downsized from 77 RP technicians (RPTs) in 1989 to 72 currently. To assist in support for radiological operations
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l REPORT DETAILS
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1.
Persons Contacted Licensee Employees
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- J. Coleman, Quality Control Supervision, Mechanical Maintenance (MM)
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- S. Coy, Radiation Protection Manager
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- W. Deal, Manager, Customer Support /GSD
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- J. Forbes, Manager, Engineering
- R. Kaye, Steam Generator Station Sponsor, Combustion Engineering
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- W. Lilly, Instructor /GSD
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- J. Lowery, Specialist, Regulatory Compliance
- W. McCollum, Jr., Station Manager
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- D. Rhen, Vice President, Catawba Nuclear Station
- G. Robinson, Quality Control, General Supervisor, MM t
- Z. Taylor, Manager, Compliance
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- J. Twiggs, Radiation Protection, General Supervisor
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Other licensee employees contacted during the inspection
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included technicians, maintenance personnel, and administrative personnel.
Other Organization i
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- P. Pappas, Owner's Group Nuclear Regulatory Commission
- R. Freudenberger, Senior Resident Inspector
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- Denotes attendance at exit meeting held.on November 19, 1993-2.
Organization and Management Controls (83729)
The inspector reviewed changes made to the licensee's organization, staffing levels and lines of. authority as they related to radiation
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protection (RP). Since the last inspection, the licensee filled the vacancy for the RP Manager position. The inspector determined that the new appointee met the qualification requirements specified in the
Technical Specification (TS). Also, it appears that the transition has
been smooth as the licensee's RP program continues to operate efficiently and effectively. The new appointee is a certified health
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physicist with good applied health physics experience.
Within the licensee's organization, three General Supervisors reported to the RP Manager, one of which has just beer. succeeded by a supervisor from Corporate RP and one General Supervisor position was eliminated.
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In discussions with licensee management, the inspector learned that the
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licensees's RP staff had been downsized from 77 RP technicians (RPTs) in 1989 to 72 currently. To assist in support for radiological operations i
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during the Unit I cycle 7 (U1C7) maintenance / refueling outage, the i
licensee transferred 29 core contract RPTs from sister plants to compliment the 15 core contract RPTs onsite.
In addition, the licensee
i contracted 45 RPTs and clerks, ninety percent of which had previously worked CNS outages.
No violations or deviations were identified.
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3.
Training and Qualifications (83729)
TS 6.8.4 requires that programs be established, implemented, and maintained for:
In-plant Radiation Monitoring; a program which will l
ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program
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shall include the following:
a.
Training of personnel;
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b.
Procedures for monitoring; and c.
Provisions for maintenance of sampling and analysis equipment.
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During tours of the Unit I containment on November 16, 1993, the inspector was observing operations in progress involving in-service
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inspection (ultrasonic inspection) of the reactor vessel. The inspector
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noted that there were approximately five people inside the
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contamination / radiation area boundary, which encompassed most of the refueling floor, when an alarm with a duration of 3-5 minutes sounded.
The inspector inquired of this. alarm with the RPT at the control point and was informed that the alarm was the containment evacuation alarm.
The two NRC inspectors exited the containment and noted that an RPT entered the refueling floor on their way out. One RPT went to the telephone and called the Control Room while the other RPT appeared to i
have a discussion with several workers in the area. The inspector observed two workers preparing to exit the area but returned to work when an RPT told them it was a false alarm. At the completion of the l
alarm an announcement from the Control Room indicated that a false alarm
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l had occurred. The inspector interviewed both RPTs and found that in fact one RPT had been on the telephone in conversation with the Control j
Room for most of the duration of the evacuation alarm. The other RPT
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stated that he had picked up a radiation detection instrument and performed a survey of the area and observed no increases in radiation I
levels during the alarm.
The inspector interviewed the duty Senior Reactor Operator (SRO) and i
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found that the noble gas monitor (EMF-39) alarmed, due to a loss of sample flow when a pump restarted and caused a spike on the radiation level monitor, thus sounding the containment evacuation alarm. The noble gas monitor had two thresholds, one at 3,360 counts per minute (CPM) and the second at 4,800 CPM. The second set point automatically i
L initiates the containment evacuation alarm.
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Since licensee personnel in containment did not initially commence
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evacuation of containment the inspemtor reviewed training to ascertain what the required response should have been by licensee personnel.
Licensee procedure HP/B/1000/41 Radiation Protection Control of Work In Containment, Revision 3, no date, requires in Section 4.1, General
Requirements, Step 4.1.2, if the Reactor Building Evacuation Alarm sounds:
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a, Immediately leave the building; and b.
Assist individuals exiting the radiological control zones.
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A review of General Employee Training (GET) showed that the same
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statement in the procedure was taught in GET for personnel to immediately evacuate the Reactor Building.
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The inspector discussed the poor performance of personnel during the I
sounding of the containment evacuation alarm with licensee management and supervision and found that work was underway to improve performance
in this area. A memorandum was issued by~ the RP Manager to all RP
. Supervisors regarding enhancing RPTs adherence to immediate evacuation of containment upon receiving a containment evacuation alarm, to notify i
others to do the same, and to perform a survey of the exit route upon
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leaving to determine if abnormal conditions exist.
In addition, the issue of poor response was discussed at the daily outage planning meeting. Regulatory Compliance issued.a memorandum to plant management l-and supervision describing the poor response to the evacuation alarm and the proper response to enhance management support for improved I
performance in this area. The inspector discussed the event with j
Regional NRC management and licensee management and it was determined that the necessary corrective actions'were in progress and the licensee
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would advise us of the outcome of their corrective actions when l
completed.
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No violations or deviations were identified.
4.
Audits and Appraisals (83729)
The inspector reviewed the licensee's program for identifying and correcting deficiencies and weaknesses related to the control of radiation and radioactive materials.
a.
Audits Technical Specification (TS) 6.5.2.9 requires audits of facility.
activities to be performed under the cognizance of the Nuclear Safety Review Board (NSRB) encompassing conformance of facility j
operation to all. provisions contained in the TSs and applicable l
license conditions, as well as the Process Control Program (PCP)
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and implementing procedures, j
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Review of selected Radiological Incident Investigation and-l Accountability Reports (RIIAR) by the inspector noted no
significant trends or indicators of RP performance problems.
Several RIIARs were discussed in detail with licensee
representatives and are addressed in the appropriate topical sections of this report. The inspector noted that the licensee-j conducted quarterly RIIAR review meetings to evaluate the various incidents, to identify any potential adverse trends, and to
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identify any corrective actions necessary to improve overall performance.
In addition to the RIIAR program, the licensee utilized the plant-
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wide Problem identification Process. (PIP) for the identification, resolution, and. tracking of radiological problems.
For RP, this
process was governed by licensee procedure HP/0/B/1000/40, Problem
Identification and Resolution Program, and encompassed potential i
problem areas such as poor radiation work pretices, adverse
trends in RIIARs,.. inadequate control of higt 'adiation areas (HRAs) and extra high radiation areas (EHRAs), contamination
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outside the radiation control area, and exposures or releases in excess of regulatory requirements.
The inspector reviewed selected PIPS associated with the RP function for the period January through October 1993, and noted
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all PIPS that documented radiological deficiencies had low priorities for resolution..The PIP system also appeared to' have too high a threshold for radiological deficiencies. In-discussions
with RP staff the inspector learned that this was why the RP group
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did not abandon the RIIAR process.
After a review of the PIPS
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that were radiologically related the inspector determined that the RP group was identifying, documenting, and resolving radiological
deficiencies. This area continues to be a program strength.
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No violations or deviations were identified.
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External Exposure Control (83729)
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Personnel Dosimetry
.l 10 CFR 20.1201(a) requires each licensee to control the
.t occupational dose to individual adults, except for planned'special
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exposures under 10 CFR 20.1206, to the following dose
.mits.
(1)
An anxal limit, which is more limiting of:
(i) the total
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effective dose equivalent being equal to 5 rems; or (ii) the
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sum of the deep-dose equivalent and the committed dose
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equivalent to any organ or tissue other than the lens. of. the eye being equal to 50 rems.
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(2)
The annual limits to the lens of the eye, to the skin, and
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to the extremities, which are:
(i) an eye dose equivalent
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to 15 rems; and (ii) a shallow-dose equivalent of 50 rems to the skin or to any extremity.
-l 10 CFR 20.1502(a) requires each licensee to monitor occupational I
exposure to radiation and shall supply and require the use of individual monitoring devices by:
(1)
Adults likely to receive, in one year from sources external to the body, a dose in excess of 10 percent of the limits in
10 CFR 20.1201(a),
(2)
Minors and declared pregnant women likely to receive, in one year for sources external to the body, a dose in excess of i
J 10 percent of any of the applicable limits of 10 CFR 20.1207
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or 10 CFR 20.1208; and
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(3)
Individuals entering a high or very high radiation area.
10 CFR 20.1502(b) requires each licensee shall monitor (see 10 CFR 20.1204) the occupational intake of radioactive material by and assess the committed effective dose equivalent to:
(1)
Adults likely to receive, in one year, and intake in excess y
of 10 percent of the applicable Annual Limit of Intake (ALI)
i in table 1, columns 1 and 2 of Appendix B to 10 CFR 20.1001.-
20.2401; and (2)
Minors and declared pregnant women likely to receive, in one year, a committed effective dose equivalent in excess of 0.05 rem.
During tours of the radiologically controlled area (RCA) of the Unit I containment and auxiliary building, the inspector noted that personnel were wearing digital alarming dosimeters (DADS)
properly. All personnel were observed to utilize the recently installed automated access system without problem. When questioned personnel were knowledgeable of their radiation work -
permit (RWP) requirements.
b.
Exposure Control
d 10 CFR 20.1501(a) veyuires each licensee to make or cause to be.
made such 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 radioactive hazards that may be present.
During tours of the Auxiliary Building, the inspector noted that the licensee had current surveys posted outside each room that had radiation levels inside.
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TS 6.12.1 requires, in part, that each high radiation area with radiation level greater than or equal to 100 mrem /hr but less than
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or equal to 1000 mrem /hr be barricaded and conspicuously posted as a high radiation area.
In addition, any individual'or ' group of individuals permitted to enter such areas are.to be provided with
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or accompanied by a radiation monitoring device which continuously indicates the radiation dose rate in the area; a radiation monitoring device which continuously integrates the radiation dose rate in the area; or an individual qualified in radiation
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protection procedures with a radiation dose rate monitoring
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device.
TS 6.12.2 requires that areas accessible to personnel with radiation levels greater than 1000 mr/hr at 18 inches be provided
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with locked doors to prevent unauthorized entry in addition to the
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requirements of TS 6.12.1.
The keys for the locked high radiation
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areas were to be maintained under administrative control.
l Licensee procedure HP/0/B/1000/25, High Radiation Area Access,
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described the licensee's specific requirements for. establishing, posting, and controlling HRAs and EHRAs. During tours of the
Auxiliary Building and Unit 1 Containment, the inspector noted that all EHRAs and HRAs were locked and conspicuously posted, as
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required.
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No violations or deviations were identified.
6.
Surveys, Monitoring, and Control of Radioactive Material and
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Contamination'(83729)
a.
Posting Radioactive Material Areas 10 CFR 20.1902(e), requires for posting of areas or rooms in which licensed material is used or stored that the licensee shall post each area or room in which there is used or stored an amount of
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licensed material exceeding 10 times the quantity of such material specified in appendix C to 20.1001-20.2401 with a conspicuous sign or signs bearing the words " Caution, Radioactive Material {s)" or
" Danger, Radioactive Material (s)."
Radiation Protection Directive No III-3, Posting of Radiation-l Control Zones, Revision 1, dated April 1, 1993, requires, in part, in step 5.4.5 to post the following areas " Radioactive Materials,"
areas where total activity stored exceeds 10 times the quantity specified in Appendix C of 10 CFR 20.
During tours of the RCA, the inspector noted that an area where radioactive materials appeared to be stored was not posted as a radioactive materials storage area.
The inspector was not able to enter the area (operations staging / storage area, elevation 565)
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because it was locked. The inspector notified a nearby RPT who later informed the inspector that the radioactive material storage il
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bag observed protruding from a storage locker in the cage was in fact empty.
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Labeling Containers of Radioactive Material 10 CFR 20.1904(a), Labeling Containers, requires the licensee to ensure each container of licensed material bears a durable,
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clearly visible label bearing the radiation symbol and the words
" Caution, Radioactive Material" or " Danger, Radioactive Material."
The label must also provide sufficient information (such as the'
l radionuclide(s) present, an estimate of the quantity of radioactivity, the date for which the activity is estimated, radiation levels, kinds of materials, and mass enrichment) to permit individuals handling or using the containers, or working in the vicinity of the cont ners to take precautions to avoid or
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minimize exposures.
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Catawba Nuclear Station Procedure, HP/0/B/1000/30, Use of l
Release / Radioactive Material Tags, in step 4.6.2, requires labels or tags on any containers of licensed material with contents
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exceeding 10 CFR 20 Appendix B, Table 1, Coluriin 2, or Appendix C.
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During tours, the inspecter did not observe any containers that i
were required to be labeled that were not in compliance with
station procedures.
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c.
Area and Personnel Contamination
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The licensee maintained approximately 184,000 square feet (ft2) as radiologically controlled. To control contamination at its source the licensee's aggressive program focuses on individual training, use of good radiological techniques, containments, and maintaining clean areas of the RCA at levels well below the limit of 1000 disintegrations per minute (DPM). The licensee has reduced the contaminated area of the RCA tn an average between 500 and
1500 square feet (FT ).
In addition, the licensee is able to
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allow minimum dress requirements (shoe covers) in upper
containment).
The tight controls on loose surface contamination has contributed to fewer personnel contamination events (PCEs). - Through the third
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quarter of this year the licensee has only experienced 83 PCEs'
with none of the events resulting in assignment of skin dose.
This number is 25 below the projection for this time in the year.
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The licensee attributed the good performance in this area to an aggressive program to control contamination at its source.
No violations or deviations were identified.
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Program for Maintaining Exposures As low As Reasonably Achievable l
(ALARA) (83729)
10 CFR 20.1101(b) requires each licensee to the extent practicable,
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procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members
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of the public that are as low as reasonably achievable (ALARA).
Regulatory Guides 2.8 and 8.10 provide information relevant to attaining
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goals and objectives for planning and operating light water reactors and provide general philosophy acceptable to the NRC as a necessary basis
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for a program of maintaining occupational exposures ALARA.
l During a review of jobs that required more than the estimated exposure
to complete, the inspector noted a number of problems with the installation of reactor coolant loop nozzle dams. Nozzle dams are
devices installed in the reactor coolant loops to contain reactor l
coolant and allow operations to be performed on the outward side of the i
nozzle dam in a dry condition.
In order to perform maintenarice on each i
of the four steam generators (S/Gs) the licensee drained the primary
side of all four S/Gs-and installed nozzle dams in eight locations (each hot and cold S/G leg).
Subsequently, manipulators (eddy current positioning devices) were installed in each of the four S/Gs. On
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November 8,1993, the licensee began filling the reactor coolant loops
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and observed water in five of the eight channel heads. The licensee secured from filling operation., and determined that channel head bowl drain plugs were installed in the wrong drain holes (installed in the manway drain hole instead of the loop drain hole).
Since disproportionate exposure was received, the licensee sought assistance from the Nuclear Steam Supply System (NSSS) vendor in i
determining the scenario of events and problems encountered. The
critique revealed the following:
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Problems encountered:
(1)
The average installation time for each nozzle dam was four minutes and 38 seconds and average time for the verification i-entry was two minutes and one second. Historically, respective times for the operations were three minutes and one minute.
(2)
Platform Technicians were unsure of how to install / tighten the drain plug.
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(3)
While tightening the nozzle dam holddown bolts, a technician noted that one of the dam sections was not aligned correctly. The installing crew was replaced and realignment and retightening commenced with a more experienced crew. No problems were encountered until the next installation crew came on shift and they experienced the same problem of nozzle dam alignment and installation as the first crew di,
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Almost every crew had problems in installation of the center
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nozzle dam section, and further problems with tightnening hold down bolts were experienced.
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In almost all channel heads the operating crew did not know l
how to install / tighten the drain plug.
b.
Contributing Training Factors
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General Services Division (GSD) personnel were not brought on site early enough. One crew only had one and a half days before performing actual installation (a contributing factor was the movement of the schedule forward).
Given that nine members compose a crew, each person received only two hours of actual
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training time. Also, a final walkthrough or dry run was not made.
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NSSS ALARA Engineers were deployed to the site too late and were
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unable to attend mockup training.
Several technicians on the nozzle dam crew had never installed a
nozzle dam before and would require additional training than that given to an experienced person.
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The proper equipment was not available to train with.
No nozzle covers were available at the mock up even though they had never
seen one before. The drain plug would not fit in the mockup correctly so the installation was simulated.
t The mockup did not resemble the actual S/G bowl in that it did not have both drain holes. When asked, most technicians answered
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there was only one drain hole in the bowl.
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The rubber diaphragm used on the mockup was old and worn and was easily maneuverable but on the actual job the new rubber seal stuck to the nozzle making it impossible to slide.
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Procedure inadequacies The installation procedure does not indicate which drain hole to install the plug into or even that there are more than one drain hole.
On November 9,1993, the licensee held a critique'of the S/G Nozzle Dam Installation operation inviting the major interfacing groups to the meeting to include the Senior Resident Inspector.
The licensee determined that areas of concern for the outage were the potential of increased outage time, increased time at hot reduced-inventory, and increased dose to personnel. A number of corrective actions were generated to correct most of the problems t
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'L identified; however, the inspector's review of the event during the inspection raised generic questions regarding training
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adequacy to the extent that suggested that training yogram corrective actions may be required.
d.
Nozzle Dam Installation / Removal Training Issue
The inspector requested compliance to coordinate a meeting with
all groups concerned with the Nozzle Dam Installation problem to i
determine if there were problems not yet identified.
The primary
_1 concerns focused on training and were planned corrective actions
sufficient to prevent recurrence. The inspector found that the procedure used for training personnel for the Nozzle Dam i
Installation / Removal was being checked out during the training
(MP/0/A/7150/099, Steam Generator Nozzle Dam Installation and Removal, Retype #3, dated March 3,-1993). The licensee stated that personnel in training did not have to complete any specific number of successful cycles of Nozzle Dam Installation or show competence in a walkthrough or a timed dryrun. That
acceptance / rejection criteria for the individual trainee rested
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with the maintenance trainer, and there were no signoffs made.in
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the training procedure under development to signify that an
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individual was trained sufficiently to perform the operation on l
the reactor. Adding significance to the issue is the fact that
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this training was performed by GSD and that GSD is expected to expand its performance of tasks for sister plants and other users i
of Duke GSD services. The licensee was unable to answer how this
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training escaped the system set up for accreditation of tasks ~for j
performance based training.
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Also, the licensee estimated that the installation of Nozzle Dams
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in all four S/Gs would take approximately 7.682 person-rem when in actuality 11.262 person-rem was expended. Approximately 31 percent of the exposure on the job was unnecessary and appeared to have been caused by having to make reentries to correct l
problems, :nd not performing the operation in satisfactory time due to intensity of radiation fields in the area.
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The inspector informed the licensee that the lack of quality training would be tracked as Inspection Follow-up Item (IFI)_50-413/93-29-01, and progress toward corrective action will be
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reviewed during subsequent inspections.
No violations or deviations were identified.
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~ Followup on Inspector Followup Items (92702)
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(Closed) VIO 50-413, 414/89-02-01:
Failure to implement adequate corrective actions for frisking and dose card deficiencies. The licensee performed the following corrective actions.
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The existing program for tracking commitments was reviewed. The program l
included all active commitments and ensures sufficient attention to meet those commitments.
A study was performed to evaluate current guidance regarding response
techniques by station workers. An assessment was made for the
availability of equipment, clothing, and health physics support.
A Station Directive was developed to provide guidance for responding to
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NRC violations.
It addressed timely corrective action, effective action
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(prevent recurrence), accurate root cause and the need for peer review.
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The inspector noted that.since the violation the station has installed
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whole body friskers and now tracks dose automatically on their exposure
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capture system. This item is closed.
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9.
Exit Meeting
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i At the conclusion of the inspection on November 19, 1993, an exit meeting was held with those licensee representatives indicated in l
Paragraph 1 of this report. The inspector summarized the inspection
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scope and discussed the findings and the previously identified violation listed below.
The licensee did not indicate any of the information i
provided to the inspector during the inspection as proprietary in nature
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and no dissenting comments were received from the licensee.
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Type Item Number Status Description i
VIO 50-413,414/89-02-01 Closed Failure to take timely corrective action for frisking deficiencies (Paragraph 8).
.l IFI 50-413/93-29-01 Open Lack of quality training -
for nozzle dam installation /
removal (Paragraph 7).
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