ML20248J479
| ML20248J479 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/31/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8904140440 | |
| Download: ML20248J479 (5) | |
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- 3 Duke Ibicer Company.
Ilu B. Tucker '
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=PO Box 33198.
Vice President Charlotte, NC 28242 Nuclear Production (704)373 4531 DUKEPOWER March 31-.1989-U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attention: ' Document Control-Desk
Subject:
Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 NRC Inspection Report No. 50-413, -414/89-02 Reply to a Notice of Violation Gentlemen:
Please, find attached a reply to violation No. '413/89-02-01 and 413, 414/89-02-02 which was transmitted per Malcolm L. Ernst's, NRC Region II, Notice of Violation.
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dated March 3, 1989. These. Severity Level IV violations involved the failure'to take adequate timely corrective action on NRC identified violations, failure to provide workers adequate training and failure to post a high radiation area.
Very truly yours,
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'H. B.' Tucker-IERPT-8/lcs
. Attachment xc: Mr. S. D. Ebneter Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101:Marietta St., NW, Suite 2900 Atlanta,' Georgia 30323 Mr. W. T. Orders NRC Resident Inspector Catawba Nuclear Station l
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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 to assure that conditions adverse to quality,.such as deviations, and nonconformances are promptly identified and corrected.
In the case of significant 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 implemented to' assure that corrective actions for identified failure to follow radiological' procedures preclude recurrence.
RESPONSE
1.
Admission or Denial of Violation
.To better understand the expectations of the
. Commission we will discuss this issue further with Fred Wright the week of April 17, 1989. We will forward a response, based on those discussions, within 30 days of Mr. Wright's visit.
We believe a number of corrective actions have been taken in the areas of frisking and Single Point Access Controls since Mr. Wright was here and would like to discuss these items before we develop our final response on this issue.
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i DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 414/89-02-02 10 CFR 19.12 requires a licensee to provide certain specified information and instructions to individuals who work in or frequent any portion of a restricted area.
10 CFR 20.203(c)(1) requires a licensee to post each high radiation area with a conspicuous sign or sings bearing the radiation caution symbol and the words:
Caution High Radiation Area.
A "high radiation area" is defined, in 10 CFR 20.202(b)(3), as any area, accessible to personnel, in which there exists raciation, originating in whole or in part within licensed material, at such levels that a major portion of the body could receive in any one hour a dose in excess of 100 millirems.
Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared consistent with 10 CFR 20 and adhered to for all operations involving personnel radiation exposure.
Technical Specification 6.12 requires that, for individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/hr that are located within large areas, such as PWR containment, where no enclosure i
exists for purposes of locking, and where no enclosure can be reasonably constructed around the individual areas, that individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device.
Contrary to the above, on December 16, 1988, two licensee employees were not provided proper information and instructions in that they unknowingly entered a high radiation area which was not posted as such and they had not received instructions concerning the significance of a flashing yellow light used to warn individuals of areas with radiation levels greater than 1000 mR/hr.
A similar violation concerning training, was cited by the NRC in a l
Notice of Violation issued September 16, 1988.
RESPONSE
l 1.
Admission or Denial of Violation Duke Power Company admits the violation 2.
Reasons for Violation if Admitted The reason for this Violation was the training 1
deficiency of two particular Duke Power workers.
This was a licensee identified event which was investigated as Radiological Incident Investigation and Accountability #88-273.
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Our investigation of this event identified a training l
deficiency.
The use of Flashing lights and it's use to I
designate Extra High Radiation Areas is covered in i
Catawba's formal GET training.
However our review discovered this was not a topic discussed in annual Update Training.
Our investigation however was incomplete and did not l
identify the fact that the individuals involved were trained outside of the Catawba Program and that a much larger training deficiency existed on a system wide scale.
Our investigation also identified that additional j
posting would have been helpful in preventing this q
event.
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We do feel that reference in this violation to a similar event described in Notice of Violation issued September 16, 1988 is incorrect.
It was a training deficiency but; it could not reasonably be expected to have prevented the training violation discussed here.
The intent of the two training items are not related and the root causes are not similar as stated.
3.
Corrective Actions Taken and Resulted Achieved Catawba GET Update Training has been revised to include information on the importance of the Flashing Light to designate Extra High Radiation Areas.
In addition, formal GET classes conducted at Oconee, and the General Office now include this instruction.
Catawba Station Directive 3.8.8 (Radiological Work Practices) included at the time of the event a clear reference to the Flashing Light and the Extra High Radiation Area.
This information however was inadequate in preventing this violation.
Station Manager Staff Notes for the week of 3-20-89 included an article on this violation, details of the event, and a discussion of our requirements.
The lEOC3 event was followed immediately by additional posting of the area to prevent recurrence.
Catawba is currently in the 2EOC2 Outage and that expanded posting has contjnued.
The installed access path to the Steam Generator Platforms has always been posted, however the ability of workers to access the platform from above by climbing down pipes and ventilation ducts had not been considered as feasible.
Our 2EOC2 controls currently include the use of cargo nets as a physical barrier to access from above along with additional signs identifying the area as a Extra high Radiation Area.
The adequacy of these controls will be evaluated during l '^
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thistoutage to determine specific changes needed to 1
enhance'our procedures.
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NRC Information-Notice 88-79:
MISUSE OF FLASHING LIGHTS FOR HIGH RADIATION AREA CONTROLS was' received at Catawba on 2/22/89fand has been; reviewed by Health Physics.
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Corrective Actions:to be Taken.toLavoid--further
~Violations Actions <taken in Section 3 above will ensure' avoidance of-further violations..
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Date of' Full Compliance Full compliance.will be achieved on 4/15/89 when HP procedure'HP/0/B/1000/31 revisions will be in place.
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