ML20237D142
| ML20237D142 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/11/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8712230075 | |
| Download: ML20237D142 (4) | |
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Dcxn POWEa GOMPANY P.O. P,ox 3'J180 cnia l:LOTTE, N.C. 26242 HALD.T.'CKER Tr:M uoxe N
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December 9 1, 1987 l
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U. S. Nuclear Regulatory Commission l
Attention: Document Contral Desk Washington, D. C. 20555
Subject:
Ca'2wba Nuclear Station Docket mm. 50-413 and 50-414 TE Report 50 413, 414/87-31-02 RII: CHB
' lear Sir:
P.hasci find attached our revised response to the Vlation 413,414/87-31~02 which was. identified in the subject Inspection Report. Thit; rustons.e replaceu in entirety the original response of November 17, 1987.)
l Very truly yours,
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,s Hal B. Tucker l
LTP/1098/sbn Attachment
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Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region II 201 Marietta l' tree t, NW, Suite 2900 Atlanta, Georgia 30323 N r. '-l., k. Van Doorn i
NRC 9 uident Inspector Catati:a fluclear Station I
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i DUKE POWER COMPANY REVISED, RESPONSE TO VIOLATION 413, 414/87-31-02 t
During the Nuclear Regulatory Commission (NRC) inspection conducted on September
.i?-10, 1987,- a violation of NMO requirements 'cas identiffsd. The' violation y
involved failure to follow proced.re for frisking and for completing daily dose
/ cards.
In accordance with the "Gineral Statement of Policy and Procedure for NRC Enforcement Actions", 10 CFR part ; 2,,.
Appendix C (1986), the violation is listed below:
i TechnicaLjspecification 6.!f requires that procedures' tar personnel radiation protect 1gn be prepared consistent with the requirement of IC: G R 20 and be approved), maintained and adhered to for all operations.invohving personnel radiatfan exposure.
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C2Eawbayucient Station Directive 3.8.3',
Contamination Prevention, Control and Decon M,Lnation Responsibilities, Revision 21, dated July 2,' 1987, requires in Section 4: 6.2.2 that personnel perform a survey for contamination when leaving a radiatior. control area (RCA).
If frisking just the hands and feet, a minimum frisk of A0 seconds is required.
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Catawba Nucle:tr Station Directive 3.8.6 (TS), Radiation Exposure Control, O
Revision 13, dated March 12,,1987, requires in Section 2.7 that all individuals c6mplate a Daily Exposure T he Record Card (DETRC) for'each entry into the 4
RCA/radie.tlon control zone (RCZ) and each change of radiaticn work permit (RWP).
1 Centrary to the nbove, Lthi ?,..iqensee failed to adhere to radiation control proceduresLin'that:
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From September 14 to September 17, 1287, ton of twelve individuals observed friskitg at the RCA access / exit. point located at the top of the spiral a
stairwsy on the 609' elevatior, frisked for only 20-25 seconds, and (2) Two individiials who worked inside an RCA/RC? on the removal, repair, or replacement. of a detecbor in the Unit 13eactor Building on August 24, 1987,
'did not complete a dailr dose card as required.
J A subsequent inspection conducted on November 16-20, 1987 pointed out a co.itinuing problem in these 3 areas, and a supplemental response was requested to the initial violation. This supplemental response wet to address specific improvements in employee conformance and management involvement. The initial response has been revised in its entirety and is presented below.
RESPOKEE (1) Adm/ssion or Denial of Violation Duko, Power Company admits the violat ion.
' ( 2. ). How ens for violation if admitted L
Failure of personnel to correctly discharge their duties as required by General Employee Training (GET) and Station procedures. The overall accessibility of the Padiation Control Area (RCA) is not administered in a
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manner'that allows management to exercise the control necessary to assure that employees are fully complying with procedures.. Management involvement has not been sufficiently strong to assure routine compliance of procedures by all employees.
(3) Corrective Actions Taken and Results Achieved (a) Station Management has received guidance from the Station Manager directing them to ensure that personnel are reminded of their responsibilities concerning dose cards and frisking.
(b) The General Employee Training program has been updated to review this violation.
(c) At Station Management request, Quality Assurance Department has conducted audits to provide station management additional information on the level of. proficiency and compliance being demonstrated by employees. This information irdicates a need for improvement and has been used in assessing the degree of change in programs and management involvement necessary to result in improved performance.
(4) Corrective Actions to be Taken to Avoid Further Violations Employee performance in frisking and dose card information can be improved through the elimination and consolidation of several frisking points and maximun use of hand and foot monitors as follows:
(a) The station will go to a Single Point Access control philosophy. All normal access to and exit from the RCA will occur at one central location. This will allow monitoring of personnel to assure compliance.
Primary compliance will still be the responsibility of the employee, however the access point can be manned as necessary to assure and reinforce-compliance initially, and then at a reduced frequency as performance improves.
(b) Provisions will be made for the movement of equipment into and out of the RCA, for personnel access to the Control Room and for flexibility during emergencies.
(c) This consolidation of access points will support redistribution of existing equipment. This redistribution of equipment will improve the quality of frisks normally performed in these areas and will improve our contamination control program.
Station Directive 3.8.3 and related documents, signs, and training will be revised to assure that primary whole body frisks (those resulting from 8/RWPs involving removal of outer clothing) will be performed in the Change Rooms. This will provide a standard monitoring location and facilitate the observation of these frisks for compliance.
Training in the form to support a 5-10 minute " Tailgate Safety Meeting" will be developed in conjunction with program revisions. Management involvement will be assured since this training is typically presented by the First Line Supervisor.
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To improve overall management involvement an immediate program of routine observations will'be implemented. The primary purposo will be to monitor for dosimetry, dose card information, frisking and general Radiological Protection requirements to evaluate compliance.
When satisfactory compliance has been achieved, a program of continuing management involvement will be 12nplemented.
The' purpose will be to assure continuing compliance is occurring.
Strong management involvement through training and random observations, combined with program improvement, consolidated access controls and better utilization of existing equipment, will correct the conditions leading up to this violation.
(5) Date of Full Compliance Duke power will be in compliance by March 1, 1988.
I This is a two month extension of our original commitment, and is necessitated by the need to relocate equipment, provide for power supplies and recalibration, and to assure that document changes and training can be completed.
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