ML20247K214
| ML20247K214 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/22/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906010243 | |
| Download: ML20247K214 (9) | |
Text
- _ _ _ _. - - - _ _ - - _ - - -.
y,.,{ ;
- (i
] 'N ~ '
DUKE POWER COMPANY
" fj '
P.O. HOX 33A80.
~ CHAllLOTTE, N.O. 28242 HALB.TUGKER reLernown.
,(704)373 4531'
[:.
t.nuctuam emonoorson vion enemment -
j' May.22, 1989 U.
S'. Nuclear Regulatory Commission
' Washington, D. C.
20555
- Attention: Document Control Desk Subj ect:
Catawba Nuclear Station, Units 1'and 2
-Docket Nos. 50-413 and 50-414 50-413,'414/89-02 NRC Inspection Report No.
Reply to a Notice of-Violation Gentlemen:
Please find attached a reply.to violation No. 414/89-02-01..which was transmitted per Malcolm L..Ernst's,.NRC Region II, Notice of Violation dated March 3, 1989.
The Severity Level IV violation' involved the failure to take adequate timely corrective action on NRC identified violations.
J Very truly yours,.
c f
l H.
Tucker
'IERPT-8/lcs Attachment xc:
Mr. S. D. Ebneter Regional Administrator, Region II
'U. S. - Nuclear Regulatory Cc ;anission 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. W. T. Orders NRC Resident Inspector Catawba Nuclear Station f
1
\\
i 8906010243 890522 PDR ADOCK 05000413 PDC a
_ _ _ =___-__ _ - _.
b 8.
DUKE POWER COMPANY
' REPLY TO A NOTICE OF VIOLATION 414/89-02-01 10 CFR 50 Appendix B Criterion XVI states that measures shall be established that conditions adverse to quality, such as deviations, and non-to assure conformances are promptly identified and corrected.
In the case of signif-icant conditions adverse _to quality,- the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, measures have not been established nor adequately Dm-plemented to assure that corrective actions for identified failure to follow radiological procedures preclude repetition. The following examples of these.
violations were given:
- Failure to conduct training for individuals handling Hot Tool Room tools.
- Failure to take timely and effective corrective action following personnel contamination events.
- Failure to adequately improve Frisking / Dose Card performance.
- Failure to conduct management observations.
- Failure to take complete corrective action following Radioactive Waste Shipment violation.
RESPONSE
- 1. Admission or Denial of Violation Duke Power Company admits and denies portions of the Violation as discussed herein.
- 2. Reasons for Violation as Admitted During Inspection 89-11 conducted April 17-21,1989 we reviewed with the Inspector the Inspection Reports referenced in this Violation, and a number of other examples of Catawba performance.
We admit that two of the referenced examples are instances where our actions were not of sufficient timeliness or effectiver.ess to preclude repetition.
Violation 50-413/87-40-03 was written for our failure to provide adequate procedures for controlling contaminated tools. Our response i
l l
n.
_ -. _=
[
~
indicated that changes would be made to the area where the contaminated tools were stored and that training of the individuals involved in handling these tools would be completed by January 31, 1988.
Subsequent Inspection 88-12 on February 22-26, 1988 revealed that the training had not been conducted as stated. The procedure controlling.
the operation of the tool room had just been approved on February 23, 1988 and the training had been postponed pending this approval.
Our failure to conduct the training was a direct personnel error. A member of station management failed to conduct the training per.our commitment.
The individual was counselled upon the importance of meeting commitment dates, and the' training was conducted.
This is a clear example of our failure to take timely corrective action and to meet commitments to the NRC.
Violation 50-413/88-27-01 was written for the failure of licensee personnel to follow plant radiological procedures which resulted in two similar contamination events over a six week period. We failed i
to take timely and effective corrective actions following the first event which.could have prevented subsequent events.
- 3. Corrective Actions Taken and Results Achieved For Admitted Violation At the time of the first Violation example (failure to conduct training) we had in place a process for tracking commitments made as a result of drills, exercises, NRC audits, QA audits, and drills / exercises onsite. In this case, even though the section involved was aware of the commitment made and the need to conduct training, one supervisor's oversight led to the violation.
As a result of this and other events it became apparent that it was necessary to improve that program. These improvements were to address three areas:
1
- 1. Develop an " ownership" on the part of the responsible section for l
planned corrective actions.
- 2. Provide for improvements in controlling extensions of due dates for implementation of corrective action.
- 3. Provide for improved review of items by Group Superintendents and Section Heads.
In addition, Catawba split its commitments into two lists, one for "in-station" commitments (e.g. drills and exercises, QA audit recommendations) and one for "out-of-station" commitments (e.g. NRC Violation responses, LER planned corrective actions, QA findings, and NRC Inspector Followup Items and Unresolved Items). This placed more of an emphasis on the " Commitment List" items and separates out the finm commitments to outside groups. This approach has improved our
<s, overall response to items as we'll,'in that three station Performance Indicators are tied to the Commitment List. Catawba tracks total Commitment List items, those that are'30 days past due, and those with.two or more due date extensions. In essence, we are managing our commitments now rather than merely " tracking" them.
- 4. Corrective Actions To Be Taken To Avoid Further Violations The existing' program (Station Directive 3.0.9) for tracking commitments ir attached for your information. Our corrective action o
will include a review of this existing program to ensure commitments are included and the program ensures sufficient attention to meet these connitments. The review will be complete and any changes needed to Station Directive 3.0.9 will be identified by the commitment date.
In addition, the Maintenance organization will review the initial violation for failure to conduct training. The review will determine if additional lessons can be learned from that event. The review will be completed and any new lessons learned will be identified by the commitment date.
The second valid example of this Violation is the citing of the two contamination events involving operators who failed to follow radiological work practices in an energency.
In an effort to improve our ability to respond during emergencies involving radiological conditions, we will conduct a study to evaluate our current guidance regarding response techniques and include an assessment of the availability of equipment, clothing, and Health Physics' support for these postulated responses. The evaluation and assessment and a schedule of any implementation activities will be completed by the commitment date.
Station management will address Station Directive guidance for responding to NRC Violations which will address timely corrective action, effective action (prevent recurrence), accurate root cause determination, and evaluate the need for peer review. This guidance.il!.1 be developed and in place by the commitment date.
1
[
- 5. Date Of Full Compliance Full compliance will be achieved on October 1, 1989.
l 1
l'
e ls L
- 6. Reasons for Violation as Denied-We are very much aware of our inspection and enforcement history Jas it pertains to adherence to radiological control procedures, and also to the perception that Catawba's corrective actions have
~
been less than effective and not in a timely manner.
The~following examples form the basis for the violation as denied:
- Frisking / Dose Card Performance
- Whole Body Frisking Equipment 1
- Management Observations
- Radioactive Waste Shipment We feel Catawba action relating to thcse issues has been timely, and effective in meeting our commitments to the NRC and to meet our own desires to operate Catawba in a radiologically safe manner, and the basis for this denial is as follows:
FRISKING / DOSE CARD PERFORMANCE Sin'ce 1985 our Health Physics programs and worker proficiency have been evolutionary. We mean by that, that the program has changed constantly in small and subtle ways and in large and deliberate ways.
Many of these changes are a result of outside influence from NRC/INPO/ANI; but many of them were a result of our 'own efforts at problem identification and resolution. These changes.have resulted in improvements.
Contamination of the station with operation has caused werkers to implement work and frisking practices that previously had only been addressed or practiced in training. Proficiency that comes with repetition was missing, and can still be a problem as conditions and personnel responsibilities change. Proficiency must be developed as responsibilities change, as new workers are hired; as vendors access the plant, and as the basic program evolves. Station Directive and program changes do not get to all levels instantaneously, and training updates may be up to a year apart. We recognize this however, and do not accept it as uncontrollable. When major changes occur, we routinely get that message to station Management through Intrastation Letters, training updates, prepared Tailgate Training packages, staff meetings, direct observation of workers, and revision of our posted instructions.
These changes have resulted in improvements.
Completion of Dose Cards is subject to the same conditions as mentioned above. It has been a continually changing program. It is also highly visible due to the fact that errors are quickly identified as data entry is made. Dose Card completion is open for the intrusion of a number of errors (some major and some minor). We treat them all alike No error is acceptable, and each is corrected with the same attention to detail. The daily change of dates, the change of Admin Limits, and the updating of TLD records mean constant attention must be directed to catching errors. An ANI change to require " signature" versus printed name meant that old habits had to be corrected by thousands of workers all across the system. However, after months of implementation, we
(,
.s m
t r.
can still detect errors.'A major improvement to our ALARA program was a change to eliminate the automatic escalation each week of Administrative Limits from 500 mrem up to 1000 mrem over the monitoring quarter. This change meant that workers had to break a years old habit of weekly escalation of the Admin. Limit when completing the Dose Card.
With time and proficiency, these errors are decreasing.
Frisking has.been a constant process of evolution for workers across the Duke system. As the company began moving away'from the standard thin window probe frisk, each station moved at a different rate based upon budgets, and availability.of'new equipment. Our own evolution-followed several, paths. As Contaminated Areas increased with: initial operation, friskers were located in new, different, and remote areas.
The proficiency and familiarity issue had to be addressed by each worker as they encountered this equipment. The multi-step process.
we went through in reducing the exits from the Radiation Control Area as our Single point Access process was implemented meant.that a changing stutus was presented to our workers, vendors, and visitors for up to a year. The implementation of automated Hand and Foot frisking presented a new challenge. Limiting some Whole Body frisk processes to. the Change Room area meant another change in the program. All of these combined over the past years to keep 100% compliance and full proficiency out of our grasp.
In our discuselons with inspectors trying to resolve issues with frisking errors, and dose card errors we did not clearly communicate the. extent of our corrective actions and management involvement in that process. We also did not clearly communicate the effectiveness that our efforts were achieving. This issue more than any other is highly dependent upon Human Factors and.as such is always subject to less than 100% effectiveness. We do not condone less than adequate performance and our well documented audit results show that. Our involvement has been timely and effective, but not well communicated during inspector visits. We will in the future devote more attention to providing examples of our effectiveness during these visits.
WHOLE BODY FRISKING EQUIPMENT NRC Inspectors are not expected tc be knowledgeable of the internal process that Catawba uses to budget funds, allocate manpower, and assign responsibility for work efforts. This fact led to a major l
COMMUNICATION failure on our part concerning the addition of Whole Body Friskers to our contamination control program. Health physics initial efforts were to obtain this equipment under the most favorable budget conditions by purchasing the equipment late in 1988 so that budget dollars would be correctly used. HP Staff manpower was dedicated I
through January 1989 to implementation of a Plant Radiological Status program. This was necessary due to budget allocations within the Duke Computer Resources unit whose support to the project was already cverbudget and dedicated only until January 31, 1989. Our intent (unstated in our response) was to begin development of plant modifications and procedures during the 2nd Quarter of 1989 with full implementation expected during the 3rd Quarter 1989. This was representative of our implementation schedule for ApTEC hand and foot monitors.
=- - _ - - _ -._-
(;.
, b.
t Catawbt did.not commit to having this equipment functional by December 1, 1988. Our. Supplemental Response dated October 28,~1988 L
to Inspection Report 50-413/88-27 clearly specified that the equipment would be'" delivered".-The delivery was a internal Duke commitment based upon 1988 budget process, and that commitment was met. It is apparent that the lack.of clarity in our response was a contributing factor in our communications failure.
In our opinion, the NRC assessment of our response as a commitment was inaccurate. We did not use language which would typically have conveyed'the intent to commit to having the equipment functional by a certain date. The NRC has the obligation to evaluate the wording of our responses to verify that the intent of the Violation was adequately and clearly addressed. In those cases where the response was not complete or was not clear; then additional communications should follow. That process did not occur in this instance. Additional discussions with the station would have easily resolved this as a example of our failure to meet commitments in a timely manner.
l MANAGEMENT OBSERVATIONS Another example of our inability to communicate clearly concerns our Supplemental Response to Violation 413/87-31-02. Our commitment said in part:
To improve overall management involvement, an immediate program of routine observations will be implemented. The primary purpose 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 implemented.
The purpose will be to assure continuing compliance is occurring.
A program of management observations was developed and conducted for a six week period. The results of this survey apparently were not discussed with a NRC Inspector during Inspection 88-27 (July 19-22, 1988) even though the program had been completed in February 1988 and reviewed with station management. The program of involvement continued through our addressing of specific needs identified during those observations.
Catawba's response to Inspection Report 88-27 included the response to Violation 88-27-01 and a attachment titled " Radiological Control Practices" which was designed to clarify any misunderstanding
.u_
m_a-m__
i
' s, e
M concerning our commitment to have in place a program of continuing management' involvement. Catawba's cover letter to Duke Power General Office Licensing personnel referenced the attachment, but was-itself poorly worded to call specific attention to'our clarification.
Duke Power response to the NRC dated October 28, 1988 transmitted the attachment but did not reference the attachment nor did it describe its purpose.This is clearly a example of NRC concern over the quality of our program, and our inability to communicate information necessary to resolve that concern.
RADIOACTIVE WASTE SHIPMENT 9
During Inspection 89-11 an additional example of incomplete corrective action was discussed concerning our response.to' Violation 87-11-01.
Our response to that Violation clearly identified that radioactive waste shipping procedures would be revised to resolve a survey documentation problem. Here again our corrective action was more involved'than we stated, in that the procedure change was actually covered with workers trained in that procedure through a formalized Employee Training and Qualification Program. If we had clearly communicated the full extent of our corrective actions during the initial response the NRC would have had a more com.plete understanding of the actual completeness of our actions.
It is apparent as we review the data utilized by the NRC in developing this Violation, that a signif'. cant misunderstanding existed. Our discussions with NRC management April 17-21, 1989 revealed that this was a communication problem that could be improved with additional effort on the part of both groups. The NRC should be more critical of responses that appear incomplete, and of commitments that are not specific.
Catawba's denial of portions of this Violation based upon the understanding that performance was adequate but poorly communicated; is not meant to cite deficiencies on the part of the NRC.
Responsibility clearly rests with the licensee to understand NRC concerns and to respond to those concerns with sufficient detail to resolve the issue. In a number of instances over the past two years, Catawba has obviously been deficient in this important area.
CONCLUSION j
We conclude 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 this Violation are the result of poor COMMUNICATION and are not poor performance.
7.
Corrective Actions Taken and Results Achieved for Denied Violation No immediate Corrective Actions were identified. See below for a discussion of Corrective Actions planned to avoid further communication difficulties with the NRC.
..a Corrective Actions To Be Taken To Avoid Further Commun'ication' 8.
Problems
- We appreciate the opportunity on April 17-21, 1989 to discuss openly with NRC management _their. assessment of our Radiological ~
Control Program and our own interpretation of'that assessment.
We now have a clear understanding of those actions that are in violation of.NRC regulations. Our full attention as discussed herein will be directed to correcting those Violations.
In a effort to better learn from this Violation, we commit to review our policies and procedures relating to development and transmittal of NRC correspondence. This review will assure that responses are worded so as to accurately convey the intent and that commitments and dates are.
clearly defined, so communication problems of this magnitude will be avoided. Station Directive guidance will be developed that addresses the format of responses, the issues that must be resolved by the response, the message to be conveyed by the transmittal letter, the basis for the commitment date, the need for supporting documentation and the objectives to be covered in any training commitment.
9.
Date of Full Compliance Full' compliance with the commitment to review correspondence processes will be complete on October 1, 1989.
- 10. Request For Review If the NRC concurs with this document, we request a review of the violation be conducted to see if the remaining " violation" examples are sufficiently substantive to warrant a violation.
)
I l
- _ _ _ _ _ _ - _ _ - - _. _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _.-