ML20214V674
| ML20214V674 | |
| Person / Time | |
|---|---|
| Site: | Catawba |
| Issue date: | 04/29/1987 |
| From: | Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20214V648 | List: |
| References | |
| 50-413-87-11, 50-414-87-11, NUDOCS 8706120235 | |
| Download: ML20214V674 (10) | |
See also: IR 05000413/1987011
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION ll
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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tiAY 0'1 1987
Report Nos.: 50-413/87-11 and 50-414/87-11,
Licensee: Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.: 50-413 and 50-414
License Nos.: NPF-35 and NPF-48
Facility Name: Catawba-1 and 2
Inspection Conducted: April 13-17,1987
Inspector:
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C'. H. Bassett
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Date Signed
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Approved by: M.
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4/c',L4 fk'7 -
C. M. Hosey, Secfyon Chief
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Date' 51gried
Division of RadiEtion Safety and Safeguards
SUMMARY
Scope: This routine unannounced inspection was conducted ~ in the area of
radiation protection including:
organization and management; training and
qualification; control of radioactive materials and contamination, surveys and
monitoring; solid radioactive waste; transportation of radioactive materials
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and followup on previous enforcement items.
Results: One violation - failure to follow procedure for documentation of
radiological surveys of radioactive material shipments.
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8706120235 870501
ADOCK 05000413
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- R. F. Wardell, Superintendent of Technical Services
- G. T. Smith, Superintendent of Maintenance
- J. H. Roach, Chief of Security
W. P. Deal, Station Health Physicist
- C. L. Hartzell, Compliance Engineer
J. W. Cox, Station Training Manager
A. Duckworth, Director of Technical Services Training
- T. K. Anderson, Director of Nuclear Security
- G. T. Mode, Support Functions Coordinator
- D. Tower, Operating Engineer
S. W. Rodgers, Radwaste Chemistry Coordinator
J. W. Willis, Senior Quality Assurance Manager
G. G. Barrett, Training Supervisor
H. F. McInvale, Surveillance and Control Coordinator
C. V. Wray, Count Room and Environmental Supervisor
G. Vander Velde, Radioactive Materials Control Supervisor
M. C. Couch, Dose Records Control Supervisor
F. L. Wilson, Respiratory / Instrument Calibration Supervisor
- P. N. McNamara, Staff Health Physicist
- M. A. Cote, Production Specialist I
J. Isaacson, Staff Health Physicist
Nuclear Regulatory Commission
- P. K. Van Doorn, Senior Resident Inspector
- M. S. Lesser, Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on April 17, 1987, with
those persons indicated in Paragraph 1 above. The inspector described the
areas inspected and discussed in detail an apparent violation for failure
to adhere to radiation control procedures (Paragraph 10).
The licensee
acknowledged the inspection findings and took no exceptions. The licensee
did not identify as proprietary any of the material provided to or
reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
(Closed) Violation 50-413/86-20-01, Failure to maintain radiation exposure
records in accordance with instructions contained on Form NRC-5.
The
inspector reviewed the licensee's responses dated August 14, 1986,
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November 6,1986, and January 29, 1987, and verified that the corrective
actions specified in the responses had been implemented.
4.
Organization and Management Controls (83722)
a.
Organization
The licensee was required by Technical Specification (TS) 6.2.2 to
implement the facility organization specified in TS Figure 6.2-2.
The responsibility, authority and other management controls necessary
for establishing and maintaining a health physics program for the
facility were outlined in Chapters 12 and 13 of the Final Safety
Analysis Report (FSAR).
TS 6.2.3 specified the composition of the
Catawba Safety Review Group (CSRG) and delineated its functions and
authority.
Regulatory Guide 8.8 also specified certain functions and
responsibilities to be assigned to the Radiation Protection Manager
and radiation protection responsibilities to be assigned to line
management.
The inspector reviewed the plant organization with the Station Health
Physicist (Radiation Protection Manager) to determine the degree of
support received from other members of management and the lines of
communication and authority.
It appeared that the support required
to implement and maintain an effective radiation control program was
in place.
b.
Staffing
Technical Specification 6.2.2 specified minimum staffing for the
plant.
FSAR Chapters 12 and 13 outlined further details on staffing.
The inspector reviewed the health physics organization and staffing
with the Radiation Protection Manager.
The attrition rate, use of
contractor health physics technicians, current staffing levels and
qualifications were discussed.
At the time of the inspection,
102 staff positions were authorized and all were filled.
In
addition, 20 contrattor technicians were onsite to augment the
experience level of the staff,
c.
Controls
The inspector reviewed the licensee's Radiological Incident
Investigation and Accountability (RIIA) Report System.
The system
appeared to be functioning as intended and problems were being
identified, corrected and investigated as required. The system also
allowed the licensee to track radiological safety concerns and
identify possible trends.
No violations or deviations were identified.
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5.
Training and Qualifications (83723)
a.
General Employee Training (83723)
The licensee was required by 10 CFR 19.12 to provide basic radiation
protection training to workers.
Regulatory Guides 8.13, 8.27, and
8.29 outlined topics that should be included in such training.
Chapters 12 and 13 of the FSAR also contained further commitments
regarding training.
The
inspector discussed the GET program with licensee
representatives.
The training provided was divided into categories
depending upon the type of work an individual was to be assigned.
Category A training was for those who needed access into the
protected area but not into Radiation Control Areas (RCAs).
The
training consisted of a two hour block of instruction followed by a
written examination.
Annual retraining was also required.
Category B training was provided for those individuals whose duties
required them to enter RCAs and observe or direct work but who were
not required to perform the work.
The training consisted of eight
hours of lecture and practical demonstrations of activities such as
donning personal protective clothing, reading pocket dosimeters and
filling cut required forms.
A written examination was administered
and retraining was required on an annual basis.
The annual
retraining could be by-passed if a passing grade could be achieved on
a written examination.
Category C training was the most extensive,
consisting of twenty hours of lectures, practical demonstrations and
individual proficiency demonstrations, and was given to those
individual doing the actual work in the plant.
An examination was
given at the conclusion of the training and retraining and retesting
annually thereafter. As in the other categories, an individual could
by-pass the annual retraining by achieving an appropriate grade
(higher than the grade required to initially pass the course) on the
examination.
Failure of individuals in Categories B or C to pass the examination
resulted in having their thermoluminescent dosimeters (TLDs) removed
from service thus restricting their access to only the protected
a rea.
Individuals in such a situation would be required to be
retrained within thirty days from the failure or fifteen months from
the date of the last examination.
The inspector reviewed the course outline and selected lesson plans
for the general employee training provided.
b.
Health Physics Technician Qualification and Training
Technical Specification 6.3 required that each member 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 stated that
technicians in responsible positions were to have a minimum of two
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years of working experience in their speciality.
The ; inspector-
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discussed the technician training program . with
licensee
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representatives.
The licensee indicated .that the Institute ~ for Nuclear power .
Operations (INP0) had extended accreditation for the training program
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at Catawba on November 20, 1986, and for 'the Duke Power Company
Training program on March 25, 1987.
c.
Contractor Health Physics Training and. Qualification
During outage periods, contractor personnel were hired to augment the
health _-physics staff and help provide adequate coverage for the .
numerous: Jobs worked.
The licensee reviewed the applications of the-
various contractor technicians and selected those deemed suitable
based on previous experience and qualifications.. Once selected, the
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contractor personnel
were given _ station orientation _and
familiarization training, selected directives and health physics
procedures for review and were required to take GET and . health
physics qualification examinations.
No violations or deviations were identified..
6.
External Exposure Control and Dosimetry (83724)
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a.
Use of Dosimeters and Postings
The licensee was required by 10 CFR 19.13, 20.101, 20.102, 20.201(b),
20.202, 20.401, 10.403, 20.405, 20.407. and 20.408 to maintain
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workers' doses below specified levels and keep records of and make
reports of doses.
The licensee was required by 10 CFR 20.203 and TS
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6.12 to post specified areas and control access to plant areas. FSAR
Chapter 12 also contained commitments regarding dosimetry and dose
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control.
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During observation of work in- the plant, the -inspector noted the
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wearing of thermoluminescent dosimeters (TLDs) _and self-reading
pocket dosimeters (SRPDs) by workers as required.
During plant -
tours, the inspector also observed the posting of areas and made-
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independent radiation measurements
using NRC equipment to assure
proper posting.
The inspector checked the security of the locks at
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numerous locked high radiation areas. and observed posted survey -
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-results.
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b.
Dosimetry Results
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The inspector reviewed the Fonn NRC-5 ' equivalent printout showing
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exposure through April 14, 1987, and verified that the radiation
doses recorded for plant personnel were within the limits of
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c.
Goals and Objectives
The inspector discussed the man-rem goals and objectives for 1986 and
1987 with the Station Health Physicist. The licensee's goal for 1986
was 540 man-rem.
However, due to various actions taken to limit
exposure such as the use of temporary shielding and mock-up training,
the actual total exposure was 284 man-rem.
The licensee indicated
that the goal for 1987 was 445 man-rem which included a refueling
outage.
No violations or deviations were identified.
7.
Internal Exposure Control and Assessment (83725)
The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403 and
20.405 to control intakes of radioactive material, assess such intakes and
keep records of and make reports of such intakes.
FSAR Chapter 12 also
includes commitments regarding internal exposure control and assessment.
Through records review and discussions with licensee representatives, it
was determined that, from January 1 to April 14, 1987, no individual
required an intake evaluation due to receiving greater than 40 Maximum
Permissible Concentration-hours (MPC-hrs) in one week.
No violations or deviations were identified.
8.
Control of Radioactive Materials and Contamination, Surveys and Monitoring
(83726)
a.
Surveys
The licensee was required by 10 CFR 20.201(b), and 20.401 to perform
surveys and to maintain records of such surveys necessary to show
compliance with regulatory limits.
Survey methods and
instrumentation were outlined in FSAR Chapter 12, while TS 6.8
provided the requirements for adherence to written procedures.
During plant tours, the inspector examined radiation levels and
contamination survey results outside selected rooms and cubicles.
The inspector performed independent radiation level surveys of
selected areas and compared them with licensee survey results.
The
inspector also reviewed several Radiation Work Permits (RWPs)
controlling general, as well as specific, work. Through discussions
with the licensee, the inspector noted that, during 1986, the
licensee maintained 8,467 square feet or 4.2% of the RCA under
contamination controls.
As of April 13. 1987, the total area had
increased slightly to 8,500 square feet t. e 4.25% of the RCA.
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b.
Frisking
During tours of the plant, the inspector observed the exit of workers
and movement of materials from the radiation control area (RCA) to
the clean areas to determine if proper frisking was performed by
workers and proper fixed and transferable contamination surveys were
performed on materials.
The inspector reviewed selected records of skin contamination
occurrences and the resulting evaluations.
Through records review
and discussions with licensee representatives, it was noted that
there had been 97 skin contaminations and 99 clothing contaminations
during 1986 and 8 skin and 18 clothing contaminations as of April 13,
1987. The records also indicated that the contamination detected had
been promptly removed from the individuals or the clothing using
routine decontamination techniques.
Subsequent whole body counts of
those contaminated indicated no detectable internal deposition of
radioactive material.
c.
Instrumentation
During area tours, the inspector observed the use of survey
instruments by health physics personnel.
The inspector examined
calibration stickers on radiation protection instruments in use and
at various areas throughout the plant.
Instrument use appeared to be
in accordance with standard practice and all instruments examined had
been calibrated.
d.
Caution Signs, Labels and Controls
10 CFR 20.203(f) required that each container of licensed radioactive
material bear a durable, clearly visible label identifying the
contents when quantities of radioactive material exceeded those
specified in Appendix C.
During plant tours, the inspector verified
that containers of radioactive material were labeled as required.
No violations or deviations were identified.
9.
SolidWastes(84722)
a.
Shipment Tracking System
10 CFR 20.311 required that the licensee maintain a tracking system
for radioactive waste shipments to verify that shipments had been
received without undue delay by the intended recipient.
The
inspector reviewed the tracking methodology used by the licensee and
examined the documented receipt acknowledgements for Shipment
Nos. CNS 87-08, 87-10, 87-14 and 87-21.
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b.
Waste Manifests
10 CFR 20.311(b) required. that each shipment 'of radioactive waste to
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a licensed disposal facility be accompanied by a shipment manifest
and specifiede required entries on theLmanifests.
The inspector
reviewed selected records of radioactive waste shipments performed
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during 1987 and verified that the manifests had been properly
completed.
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c.
Waste Classification
The licensee was required by 10-CFR;20.311(d)(1) to prepare all
wastes so that the waste was classified in. accordance Lwith
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10 CFR.61.55. . The licensee used a computer code supplied by a vendor
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to classify. their wastes.
Using the licensee's procedure, the
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inspector verified calculations of waste classification based 'on
nuclide concentrations listed on selected.1987~ shipping papers.
d.
Scaling Factors
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10-CFR 61.55(a)(8) stated that the concentration of a radionuclide
may be determined by indirect methods such .as the use of scaling
factors which relate the inferred concentration of one radionuclide
to another that is measured if there is reasonable assurance that the
indirect method can be correlated with actual measurements.
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The licensee's General Office (GO) had computed current, plant-
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specific scaling factors for the facility based upon waste stream
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analyses of bead resin, spent filter media and dry active' waste
(DAW). These scaling factors were being used as were scaling factors
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implemented in January 1986 for evaporator concentrates and powdex
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resin.
Licensee representatives indicated that updated scaling
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factors for powdex resins would be computed during 1987.
e.
Waste Stability
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The licensee was required by 10 CFR 20.311(d)(1) .to prepare all waste
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so that the waste would meet the waste characteristic requirements--
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specified in 10 CFR 61.56.
The inspector disuJssed the program for waste characterization with
licensee representatives. The licensee.did not' anticipate that waste-
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solidification would be performed frequently, and at the time of the
inspection, .no solidification of waste had been -performed.- Waste'
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processing that had been performed was conducted by a vendor and
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consisted of dewatering bead resins.
These were placed in approved
containers .for shipment.
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f.
Radwaste Shipments
Through discussions with licensee representatives, it was noted that
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6,804 cubic feet (ft3) of solid radioactive wastes containing
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13.26 curies of activity had been shipped from the facility during
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1986.
Through April 13, 1987, the licensee had made five waste
shipments consisting of 1,779 ft3 of waste containing 80.5 curies of
activity.
A total of 912 ft3 of waste remained in storage awaiting
shipment.
No violations or deviations were identified.
10. Transportation (86721)
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The licensee was required by 10 CFR 71.5 to prepare shipments of
radioactive material in accordance with Department of Transportation (DOT)
reguletions in 49 CFR parts 170 through 189.
The inspector reviewed
selected records of shipments of radioactive material made during 1987.
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The inspector verified that the licensee was registered with the NRC to
utilize the packages used for those shipments.
Technical Specification 6.8.1 requires that written procedures be
established, implemented and maintained covering applicable procedures
recommended in appendix A of Regulatory Guide 1.33, Revision 2,
February 1978.
Appendix A, Regulatory Guide 1.33, Paragraph G.5.C recormiends that the
licensee have radiation protection procedures to control surveys and
monitoring.
Radiation Control Procedure HP/0/B/1006/12, Shipment of Dewatered Resins,
dated April 2,1987, required in Step 4.12.1 that an exit survey be
performed on a loaded vehicle and that radiation levels be listed for
points one-half inch (contact) and two meters from the vertical plane
projected from the outer edges of the vehicle and inside the cab.
Upon reviewing the records of the radioactive waste shipments made during
the first quarter of 1987, the inspector noted that some of the
information required by the shipping procedure was missing.
Records of
Radioactive Material Shipments LBD 87-13 shipped on February 23, 1987, and
CNS 87-21 shipped on March 20, 1987, did not list any radiation levels
inside the cab of the vehicle.
Records of radioactive material shipments
CNS 87-10 shipped on February 6,1987, and CNS 87-13 shipped on February
23, 1987, did not list radiation levels at a point two meters from the
vertical plane of the vehicle.
The inspector discussed the missing survey data with licensee
representatives including three of the technicians who perform the
shipping surveys.
The licensee indicated that the radiation surveys had
included the levels in questions but that the data had not been listed as
required.
It was also noted that there was nothing on the shipping survey
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maps that would remind the technician to list all the required data and
the licensee stated that that would be corrected and specific, labeled
spaces would' be provided to preclude the omission of required. data in the
future.
Failure of the licensee to adhere to radiation centrol procedures by not
listing the required radiation levels inside the cab of-the vehicle and at
a point two meters from the vehicle was identified as an apparent-
violation of TS 6.8.1(50-413/87-11-01).
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