ML20245J214
| ML20245J214 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/02/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tucker H DUKE POWER CO. |
| References | |
| NUDOCS 8908170581 | |
| Download: ML20245J214 (6) | |
See also: IR 05000413/1989002
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Duke Power Company
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-ATTh: Mr. H. B.-Tucker, Vice President
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Nuclear Production Department
422 South Church Street
' Charlotte, NC: 28242
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Gentlemen:
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SUBJECT: NRC INSPECTION REPORT NOS. 50-413/89-02 AND 50-414/89-02
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_Thank you for your responses of March 31, 1989, May 22, 1989, and May 26, 1989,
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to our Notice of Violation-issued on Mcrch 3,1989, concerning activities
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conducted at your Catawba facility. We have examined your responses and found
that they meet the requirements of _10 CFR 2.201.
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In' your_ response, you' admitted and denied portions of the violation and -
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requested the NRC: review the-violation to see if the remaining examples of
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inadequate corrective action were substantive enough to warrant a violation.
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. After. careful consideration.of the bases for your denial of the violation, we
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have concluded,' for the reasons presented in the enclosure to the letter, that
the violation occurred as stated in the Notice of Violation. Therefore, in
accordance with 10'CFR 2.201(a), please submit to this office within 30 days of
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.the date of this letter a written statement describing'the steps which have been
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taken to correct the violation and the results' achieved, corrective steps which
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will be taken to avoid further violations, and the date when full compliance.
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will be achieved.-
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In accordance with Section 2.790 'of the NRC's " Rule of Practice," Part 2,
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Title.10, Code of Federal Regulations, a copy of this . letter and its enclosure
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will be placed in the NRC Public Document Room.
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The responses directed by this letter and its enclosure are not subject to the
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clearance procedures of. the Office of Management' and Budget as required by the
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Paperwork Reduction Act of 1980, Public Law No.96-511.
We appreciate your cooperation in this matter.
Sincerely,
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fOCLI Glhned
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Stewart D. Ebneter
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Regional Administrator
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' Enclosure:
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Evaluations and Conclusions
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Duke Power Company
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T. B. Owen, Station Manager
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NRC Resident Inspector
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ENCLOSURE
EVALUATIONS AND CONCLUSION
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On March 3,1989, a Notice of Violation (50-413/89-02-01) was issued for a
violation identified during a routine NRC inspection. Duke Power Company
responded to the Notice on May 22, 1989, and admitted and denied portions of the
violation. The licensee also requested that the NRC review the denied violations
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and determine if the admitted violations warranted the issuance of a violation.
The NRC's evaluations and conclusions regarding the licensee's arguments are as
follows:
Restatement of Violation A
10 CFR 50, Appendix B, Criterion XVI states that measures shall be established
to assure that conditions adverse to quality, such as deviations, and
nonconformances, are promptly identified and corrected.
Contrary to the above, measures have not been established nor adequately
implemented to assure that corrective actions for an identified failure to
follow radiological procedures preclude recurrence, as evidenced by the
following:
1.
In September 1987, NRC Inspection Report Nos. 50-413, 414/87-31 identified
a failure to follow radiation control procedures relative to proper
contamination monitoring and use of daily dose records.
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In November 1987, NRC Inspection Report Nos. 50-413, 414/87-40 identified
an example of failure to follow radiation control procedures relative to
proper contamination monitoring.
3.
In July 1988, NRC Inspection Report Nos. 50-413, 414/88-27 identified the
failure to implement all of the corrective actions for the above violations
by a March 1, 1988 completion date.
4.
A licensee audit conducted in December 1988 (LN-88-34) identified the
failure to frisk hand held items leaving the Radiological Control Area
(RCA) in- accordance with licensee procedures, dose cards not being
completed for each entry / exit of the RCA, and employees exiting the RCA
from areas that were not normal exit points.
Summary of Licensee's Response
Duke Power Company admitted and denied portions of the violation.
Partial Admission of Violation A
The licensee admits that their actions associated with NRC Violations
50-413/87-40-03 and 50-413/88-27-01 were not of sufficient timeliness or
effectiveness to preclude repetition.
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Enclosure.
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NRC violation 50-413/87-40-03 was issued for fcilure to have adequate
written procedures for controlling contaminated tools in the licensee's hot tool
room. The licensee admitted that training on the proper controls for
contaminated tools in the hot tool room had not occurred by the licensee's
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corrective action completion date. The licensee stated that failure to conduct
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the training was a personnel error and that the individual was counseled on
the importance of meeting commitment dates.
NRC violation 50-413/88-27-01 was issued for the failure of operations personnel
to follow radiological control procedures, on two occasions, while responding to
leaking radioactive systems. The licensee admitted that they had failed to take
timely and effective corrective actions following the first event which could
have prevented the subsequent event.
The licensee's corrective action included
discussing the incidents with the individuals involved and discussing the event
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in an Operations Shift Supervisor's Meeting.
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partial Denial of Violation A
The licensee contends that their corrective action program for radiological
protection procedure violations has been timely and effective for frisking and
dose card activities (50-413/87-31-02) and radioactive waste shipment surveys
(50-413/88-27-01).
Regarding the 50-413/87-31-02 violation, the licensee reported that numerous
changes in the frisking and dose card activitics had taken place in the last
five years and these program changes had kept the licensee from 100 percent
compliance and full proficiency.
The licensee also discussed the activities associated with the purchase and
introduction of new whole body friskers in their contamination control program.
The licensee stated that the NRC was incorrect in assuming that it was the
licensee's intent to install and operate the whole body friskers by the end of
1988.
Although Attachment I to their Reply To A Notice Of Violation
50-413/88-27-01, dated October 28, 1988, cledrly specified that the equipment
would be " delivered" late that year, Catawba did not commit to have the
equipment functional by December 1, 1988.
The licensee reported that another example of ineffective communication with the
NRC involved a corrective action commitment for NRC Violation 50-413/87-31-02.
In order to improve overall management involvement in correcting frisking and
dose card problems, the licensee committed to implement a program of routine
observations to monitor employee compliance with dosimetry, dose cards, frisking,
and general radiological protection program requirements. The licensee conducted
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a program of management observations for a six week period. The licensee
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reported that the results of the survey apparently were not discussed with the
NRC Inspector during the July 1988 inspection (Inspection Report No. 88-27) even
though the program review had been completed in February,1988.
The licensee
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stated that an attachment to the response to NRC Violation 50-413/88-2/-01 was
designated to clarify any misunderstanding concerning their commitment to have
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Enclosure
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in place a program of continuing management involvement. However, the Duke Power
response to Violation 50-413/88-27-01 did not reference the attachment nor
describe its purpose.
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The licensee reported that 'during the 1989 inspection (Inspection Report
No. 89-11), the inspector discussed an additional example of inadequate
corrective action concerning the licensee's response to Violation
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50-413/87-11-01. Violation 50-413/87-11-01 documented the licensee's failure to
adhere to radiation control-procedures by not listing the required radiation
levels inside the cab of a transport vehicle and at a point two meters from the
vehicle. The licensee stated that they had implemented additional corrective
action for the violation that had not been included in their proposed corrective
action to the NRC. The licensee reported
that in addition to revising the
radiot.ctive waste shipping procedures they had covered the procedure revisions
with hot tool room workers in a formalized Employee Training and Qualification
Program.
The licensee's response also stated that a significant misunderstanding existed
between the licensee and the NRC and that communications could be improved with
additional effort on the part of both groups. The licensee concluded that the
use of certain performance examples by the NRC (frisking errors, dose card
errors, management involvement, missed whole body frisker commitments) as the
basis for the violation are the result of poor communication and not poor
performance.
NRC Evaluation
The NRC staff has carefully reviewed the licensee's response and has concluded
that the licensee did not provide any information that was not already
considered in determining the significance of the violation. The NRC does
agree that the communication could have been better on behalf of the licensee
and the NRC concerning the scope of proposed corrective action and the
implementation schedules.
However, the NRC does not agnee with the licensee's
assessment that there was only a communication problem between both parties.
As stated in NRC Violation (50-413/89-02-01), the NRC identified failure to
adhere to radiological control procedures for personnel contamination monitoring
and completion of daily dose cards in September of 1987. The NRC documented
failure of licensee personnel to properly perform personnel contamination
monitoring again during a subsequent inspection conducted in November of 1987.
Furthermore, Licensee Surveillance CN-88-34 conducted in December of 1988,
documented continuing failure of licensee personnel to comply with licensee
radiological protection procedures for frisking, exiting the RCA, and
completing daily dose cards.
These series of examples of failure to perform
proper personnel contamination monitoring formed the basis for the violation for
failure to take adequate corrective action. Although the licensee did in fact
take several steps to correct the problem with such surveys, the failure to
perform adequate contamination surveys continued.
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Enclosure
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.With respect to the licensee's corrective action for NRC Violation
-50-413/87-31-02, the NRC staff concluded that there was a communication
problem with both parties concerning the licensee's plan for management
review of radiological protection procedural compliance. During NRC
Inspection Report No. 50-413/89-11, the NRC Inspector considered the results of
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the Catawba's management review which was completed by the licensee in February
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of 1988. The inspector informed the licensee that the corrective action for NRC
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Violation 87-31-02 appeared to be complete. Accordingly, our records concerning
the licensee's corrective action for management review of radiological practices
will be revised.
There were several reasons for closing NRC Violation 50-413/87-31-02 even
though corrective action for the violation was still a concern for the NRC
staff.
During the 50-413/89-11 inspection, the inspector determined that the
licensee had installed the new whole body friskers at the main RCA exit and in
the licensee's change rooms.
The installation of the whole body friskers
improved the licensee's personnel contamination program significantly and
reduced the potential for personnel frisking errors associated with the use of
small thin window Geiger-Muller detectors.
NRC Conclusion
For the above reasons, the NRC staff concludes that the violation occurred as
stated.
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