ML20214V674

Insp Repts 50-413/87-11 & 50-414/87-11 on 870413-17. Violations Noted:Failure to Follow Procedure for Documentation of Radiological Surveys of Radioactive Matl Shipments

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: ML20214V644 ML20214V665 ML20214V674
References
50-413-87-11, 50-414-87-11, NUDOCS 8706120235
Download: ML20214V674 (10)

See also: IR 05000413/1987011

Text

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v Rico, UNITED STATES

f o NUCLEAR REGULATORY COMMISSION

U\ gr REGION ll

N I E 101 MARIETTA STREET, N.W.

E 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: G.. b f/e29/87

,

C'. H. Bassett [] Date Signed

Approved by: M. 'n b 4/c',L4 fk'7 -

C. M. Hosey, Secfyon Chief .

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

PDR ADOCK 05000413

G PDR

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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 l

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 I

to adhere to radiation control procedures (Paragraph 10). The licensee I

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-

discussed the technician training program . with licensee ,

representatives.

The licensee indicated .that the Institute ~ for Nuclear power .

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Operations (INP0) had extended accreditation for the training program

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

1 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

I 6.12 to post specified areas and control access to plant areas. FSAR

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Chapter 12 also contained commitments regarding dosimetry and dose

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control.

During observation of work in- the plant, the -inspector noted the

j 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-

i 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. '

,- b. Dosimetry Results

The inspector reviewed the Fonn NRC-5 ' equivalent printout showing

i exposure through April 14, 1987, and verified that the radiation

doses recorded for plant personnel were within the limits of

l 10 CFR 20.101.

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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

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10 CFR 20.311(b) required. that each shipment 'of radioactive waste to  !

a licensed disposal facility be accompanied by a shipment manifest I

and specifiede required entries on theLmanifests. The inspector

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reviewed selected records of radioactive waste shipments performed

during 1987 and verified that the manifests had been properly

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completed.

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

inspector verified calculations of waste classification based 'on

nuclide concentrations listed on selected.1987~ shipping papers.

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d. Scaling Factors

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

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indirect method can be correlated with actual measurements.

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i- The licensee's General Office (GO) had computed current, plant-

3 specific scaling factors for the facility based upon waste stream

! analyses of bead resin, spent filter media and dry active' waste

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(DAW). These scaling factors were being used as were scaling factors

implemented in January 1986 for evaporator concentrates and powdex

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resin. Licensee representatives indicated that updated scaling

factors for powdex resins would be computed during 1987.

e. Waste Stability

. 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--

! specified in 10 CFR 61.56.

The inspector disuJssed the program for waste characterization with

licensee representatives. The licensee.did not' anticipate that waste-

1 solidification would be performed frequently, and at the time of the

inspection, .no solidification of waste had been -performed.- Waste'

{ 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 ,

6,804 cubic feet (ft3) of solid radioactive wastes containing )

13.26 curies of activity had been shipped from the facility during I

Through April 13, 1987, the licensee had made five waste

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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. 1

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 l

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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 l

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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