ML20246L672

Insp Repts 50-413/89-02 & 50-414/89-02 on 890130-0203. Violations Noted.Major Areas Inspected:Preoutage Planning, Preparations & Mgt Support for Implementing Licensee Radiation Protection Program

ML20246L672
Person / Time
Site:	Catawba
Issue date:	03/03/1989
From:	Potter J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20246L645	List: ML20246L639 ML20246L659 ML20246L672
References
50-413-89-02, 50-413-89-2, 50-414-89-02, 50-414-89-2, NUDOCS 8903240244
Download: ML20246L672 (15)

See also: IR 05000413/1989002

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f'p o%g4L UNITED STATES

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[ NUCLEAR REGULATORY COMMISSION -

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lf- REGION il

101 MARIETTA ST., N.W. q

eo,, ATLANTA, GEORGIA 30323 g

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11AR 0 31989

Report Nos.: 50-413/89-02 and 50-414/89-02

Licensee: Duke Power Company

.422 South Church Street

Charlotte, NC 28242

Dccket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and NPF-52

-Facility Name: Catawba 1 and 2

, . Inspection Conducte : J nuar 30 - February 3, 1989

Inspector: 8 /

A F. N(Wright pifeSigned

Approved by:

J. M Potter, Chief

8 /f

D'at'e Signed

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Facilities Radiation Protection Section

Emergency Preparedness and Radiological Protection

Branch

Division of Radiation Safety and Safeguards

SUMMARY

Scope

This routine, unannounced inspection was conducted in the areas of pre-outage

planning, preparations, and management support for implementing the licensee's

radiation protection program. The review included: licensee organization and

management controls; maintaining occupational exposures as low as reasonably

achievable (ALARA); training and qualifications; outage preparations and

provisions; and licensee action on previously identified inspection findings.

Results

Two violations of NRC requirements were identified:

1. Failure to take adequate timely corrective action on NRC identified

violations.

2. Failure to provide licensee workers adequate training on the

. significance of yellow flashing lights, and failure to post the

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associated high radiation area. This was similar to a violation

concerning training cited in a Notice of Violation issued

September 16, 1988.

The input from section supervisors on methods to further reduce

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occupational radiation exposure was found to be minimal, although the

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person-rem totals per unit were low for a facility having two partial

refueling outages during the year.

The outage radiological controls were generally effective even

though there had been a reduction in radiation protection technician

support when compared to previous outages.

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REPORT DETAILS j

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L1. Persons Contacted

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Licensee Employees

• V. _Barbour, . Quality Assurance, Director of Operations 1

W. Bradley, Manager, Quality-Assurance Verification  !

• W. Deal, Station Health Physicist  :

A. Duckworth, Director, Technical Services Training

• R. Glover, Compliance Engineer

'*V. King, Compliance Engineer

• P. LeRoy, Regulatory Compliance

T. Owens~ Station Manager ,

R. Rivard, ALARA Planning Supervisor

Other' licensee employees contacted during this inspection included

technicians and office personnel.

Nuclear Regulatory-Commission

• M. Lesser, Resident Inspector

• W. Orders, Senior Resident Inspector

• Attended exit interview

2. Organization'n and Management Controls

Through interviews with the licensee's staff, the inspector reviewed-the

licensee's health physics (HP) outage organization plans, staffing levels,

lines of_ authority and degree of interaction with other plant work groups,

a. Health Physics Organization

The licensee had a HP staff which was' highly specialized, in that,

the staff was divided into small units having specific areas of

responsibility. During refuelina outages the licensee's four

surveillance and control (SC) orups were deployed to provide

continuous HP outage support in the auxiliary and containment

buildings.

The licensee used contract HP supervisors for steam generator and

auxiliary building work. The licensee contracted with approximately

ten supervisors and one hundred ANSI qualified HP technicians to

provide for outage surveillance and control activities. In areas

where. the licensee did' not have utility employee supervisors, the

licensee tries to place experienced ANSI qualified licensee HP

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technicians to control work. The licensee also used contract

technicians and clerical help in the HP support units.

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Through interviews with licensee representatives, the inspector

determined that the ' licensee had used approximately 180 contract HP

support personnel during previous outages. During the Unit 1 Cycle 3

outage, the licensee had reduced the number of contract support

personnel by 10 percent and was planning to have 15 fewer contract j

support personnel during the Unit 2 Cycle 2 refueling outage. These j

reductions were being made in the licensee's radiation protection j

staffing levels in an effort to reduce utility expenses. Licensee

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representatives, in the HP section, reported that the reductions in

outage staffing levels had not adversely affected the licensee's

ability to implement the radiation protection program. Except as

noted in Paragraph 2.c. and 4 of this report, the inspector found that

appropriate radiological controls were being implemented with this

reduced staffing-level.

No violations or deviations were identified.

b. Licensee Audits 3

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Technical Specification (TS) 6.11 requires that procedures for

personnel radiation protection be prepared consistent with the

requirement of 10 CFR 20 and be approved, maintained, and adhered to

for all operations involving personnel radiation exposure.

Catawba Nuclear Station (CNS) Directive 3.8.3, Contamination

Prevention, Control and Decontamination Responsibilities,

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Revision 24, dated November 29, 1988, requires in Section 4.6.2.2

that personnel perform a survey for contamination when leaving a

radiation control area (RCA). If frisking just the hands and feet, a

minimum frisk of 40 seconds is required.

CNS Directive 3.8.6 (TS), Radiation Exposure Control, Revision 17,

dated November 21, 1988, requires in Section 2.7 that all individuals

complete a Daily Exposure Time Record Card (DETRC) for each entry

into the RCA/ radiation control zone (RCZ) and each change of I

radiation work permit (RWP).

The inspector reviewed licensee Quality Assurance (QA) Surveillance

Audit CN-88-34 which was conducted December 5-9, 1988. The

surveillance reported the following radiological control findings on

January 27, 1989.

(1) Employees were exiting an RCA from areas that cre not normal i

exit points (i.e., back door of Auxiliary Building,  !

elevation 594' and Unit 1 Control Room location).

(2) Hand held items were not being frisked.

(3) Dose cards were not being completed for each entry / exit of RCA

(mostly at Unit 2 entry / exit point)

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(4) A HP Technician (Vendor) was reaching into the RCZ and

performing work without being dressed in accordance with the

RWP.

As a result of the findings, the licensee terminated the vendor HP

technician that had violated the RWP requirements. The Station

Health Physicist also issued a letter to station management

concerning the audit. The letter, Intrastation Letter to Group

Superintendents and Section H ea.ds , issued December 29, 1988,

addressed radiation protection practices relative to the QA

-Surveillance Audit CN-88-34. The letter, in part, discussed the

following conditions:

- Employees were observed exiting the RCA at points other than the

Single Point Access (SPA). The exit points observed did not

meet procedural requirements for emergency conditions or

escorting of material. One observed exit at the Material j

Control Point did not include the required hand and foot frisk. i

Several exits were discovered to be into and out of the Control

Room using the Unit 1 side access, as well as the access door to

the ventilation equipment room. Both doors were clearly marked

as not being an exit and, in addition, did not have any frisking

equipment.

- A similar situation was discovered by HP when personnel were  !

detected exiting at the 560' elevation below the SPA. This exit

also had no frisking equipment available. This door was clearly

marked as not being an RCA exit. These persons were challenged

and given preper instruction.

- Frisks of hand held items were observed to be inadequate (not

frisked at all or frisked too fast). Many of these observations

were made at the Unit 2 Control Room entrance / exit.

- Dose cards were not completed for each entry / exit from the RCA.

Most of these observations also occurred at the Unit 2 Control

Room extrance/ exit. For these observations, the individual was

identified by the auditor, and dose card records were audited

the next day and no dose record was available.

- A contract HP technician was observed reaching into an RCZ and

performing work without meeting dress requirements. HP action

was to terminate the individual immediately.

In addition, the licensee issued a CNS Radiological Protection

Practices Training Package as an attachment to the letter. The

training package was prepared for section supervisors for use in crew

tailgate meetings. The report findings of hand held items nei being

frisked and dose cards not being completed for each exit of 1he RCA

in accordance with the above requirements were recurring examples of

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the earlier violation issued in Inspection Report (IR) No. 50-413,

414/87-31'.

c. Management Controls and Corrective Action

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.

TS 6.11 requires that procedures for personnel radiation protection I

be prepared consistent with the requirements of 10 CFR 20 and be

approved, maintained and adhered to for all operations involving i

personnel radiation exposure.

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CNS Directive 3.8.3, Contamination Prevention, Control and

Decontamination Responsibilities, Revision 24, dated November 29,

1988, requires in Section 4.6.2.2 that personnel perform a survey for

contamination when leaving the RCA. If frisking just the hands and

feet, a minimum frisk of 40 seconds is required.

CNS Directive 3.8.6 (TS), Radiation Exposure Control, Revision 17,

dated November 21, 1988, requires in Section 2.7 that all individuals

complete a DETRC for each entry into the RCA/RCZ and each change of ,

the RWP.

IR No. 50-413, 414/87-31 documented the results of an inspection made

September 14-18, 1987. A Severity Level IV violation (50-413,

414/87-31-02) was issued for failure to adhere to radiological

control procedures in that:

(1) From September 14 to September 17, 1987, ten of twelve

individuals observed frisking at the RCA access / exit point

located at the top of the spiral stairway on the 609' elevation,

frisked for only 20-25 seconds and;

(2) Two individuals who worked inside an RCA/RCZ on the removal,

repair, or replacement of a detector in the Unit 1 Reactor

Building on August 24, 1987, did not complete a daily dose card

as required.

On November 17, 1987, the licensee responded to the violation issued

in IR No. 50-413, 414/87-31 for violation 87-31-02. The NRC reviewed l

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the licensee's proposed corrective action and determined that the

proposed corrective action was not sufficient to prevent recurrence, (j

and a supplemental response was received dated December 11, 1987, and

with clarification, it was accepted in an NRC letter dated i

January 15, 1988.

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On' December 10, 1987, the NRC issued IR No. 50-413, 414/87-40. In

Paragraph 7 of the. report, the inspector reported numerous examples

of personnel failing to perform personnel monitoring in accordance

with licensee procedures. The Notice of Violation described a

L failure to properly store contaminated tools and post a copy of a

previous' Notice of Violation.

On April 7,1988, the NRC issued IR No. 50-413,414/88-12 for an

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i' inspection made on February 22-26, 1988. In Paragraph 4.f of the

report, the inspector reported on discussions held with licensee

representatives.concernin

Single Point Access (SPA)g .

the uses

Licensee and limitations

representatives of the personnel

indicated that

they were still evaluating the adequacy of the SPA in minimizing the

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. potential of low level contamination leaving the RCA. The inspector

noted that the HP technician nearest to the area was located one

level above and could only be reached by telephone. The

tools / equipment frisking station was also located one elevation above

the exit. Some individuals were confused about whether items frisked

at the tools / equipment frisking station must be frisked again at the -

SPA. . Licensee representatives acknowledged the inspector's comments

and agreed:to evaluate equipment release practices.

The inspector noted that the signs regarding personnel monitoring in

the men's change room, next to friskers indicated that the frisker:

were there for " convenience". Licensee representatives had indicated

that personnel contamination surveys were " required" in the change

rooms when personnel had been working in contaminated areas.

Licensee representatives indicated that they would reevaluate the

adequacy of the signs.

On September 16, 1988, the NRC issued IR No. 50-413, 414/88-27,

documenting a violation involving the failure of operations personnel

to follow radiological control procedures on two occasions during

responses to stop leaks in radioactive systems. The report also

documented the licensee's failure to take full corrective action for

violation 50-413, 414/87-31-02.

The licensee's response to these violations indicated that an

immediate program of HP SPA routine observations would be implemented

to improve compliance with the frisking and dose card requirements

and they would be in full compliance on March 1,1988. However, as

of July 19-22, 1988, the program of routine observations had not been

implemented. The inspector noted that this was the second time in as

many inspections that the licensee had failed to meet all aspects of

their commitments to the NRC by the date established by the licensee.

The cover letter for the September 16, 1988 NRC report discussed the

licensee's failure to take full corrective actions on the violation

50-413, 414/87-31-02, and for another violation 50-413, 414/87-40-03,  ;

The cover letter stated that the NRC views failure to take full

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corrective action on these radiological safety as a serious matter.

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On October 28, 1988, the licensee issued their response to the

Severity Level IV violation issued in IR No. 50-413, 414/88-27 which

included, management audit of several new records at Catawba such as:

HP Problem Reports

Dose Card Error Reports 4

Single Point Access Logbook

Radiological Incident Investigations

The licensee also discussed continuing management involvement in

ALARA training and pre-outage meetings and that hand and foot

monitors had been purchased and placed in service throughout the

plant. The licensee reported that whole body friskers had been

purchased and would be delivered in late 1988.

The licensee addressed the corrective action associated with the hot

tool room prncedure violation discussed in IR No. 50-413,414/87-40.

-The licensee listed these corrective actions for the root .cause of.

the problems:

Organizational changes were made which allowed the technical and

work execution aspects of the maintenance group to be separated. !

A new position was created that would separate the technical and

executional aspects of a job. The licensee stated that "with

better job planning packages available, the execution crews can

now devote full attention to procedures, training, and improving

performance."

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The inspector attempted to verify completion of corrective action for

violation 50-413, 414/87-31-02. However, during the inspection, as

detailed in Paragraph 2.b, the inspector noted a QA Surveillance made

in December 1988, which documented additional examples of failure to i

perform contamination frisks in accordance with licensee procedures  !

and failure to complete daily dose cards in accordance with licensee

procedures.

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These findings by the licensee are additional examples of failure to  ;

follow procedures and indicate a failure to take adequate and timely  !

corrective action sufficient to preclude recurrence of a similar

violation cited on September 16, 1988. Failure to take adequate and

timely corrective action is therefore, a violation of 10 CFR 50,

Appendix B, Criterion XVI (50-413/89-02-01).  ;

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One violation was identified.

3. Outage Planning and ALARA Activities

10 CFR 20.1.c states that persons engaged in activities under licenses

issued by the NRC should make every reasonable effort to maintain

radiation exposures ALARA. The recommended elements of an ALARA program

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radiation exposures ALARA. The recommended elements of an ALARA program

are contained in Regulatory Guide 8.8, Information Relevant to Ensuring

That Occupational Radiation Exposure at Nuclear Power Stations will be l

ALARA, and Regulatory Guide 8.10, Operating Philosophy for Maintaining -

Occupation Radiation Exposures ALARA.

a, ALARA

The inspector reviewed the licensee's program for maintaining

occupational exposures ALARA, including the station's ALARA goals and

objectives, the effectiveness in setting and meeting ALARA goals,

participation by different station groups in the ALARA program, and

the functions of the onsite ALARA group.

The licensee's ALARA goal for 1988 was 552 person-rem. The goal was

based on the licensee's task schedule for the year and the licensee's

person-rem exposure history for .the planned work. The integration

scheduling staff provided the ALARA group with a list of planned

tasks. The ALARA group reviewed the job history files and

established an ALARA package for jobs which are expected to exceed

one person-rem exposure. The ALARA packages included detailed job

dose reduction recommendations, copies of RWPs, surveys, and other

information obtained in previous work experience for the job. The

inspector reviewed selected ALARA planning packages and determined

that dose exposure reductions were being made through in depth ,

planning and application of basic ALARA techniques.

Through interviews with licensee representatives, the inspector

determined that the ALARA group had solicited comments and dose

reduction recommendations from section supervisors on the 1988

exposure estimates and that only one supervisor had commented on his

section's estimated exposure for the year. The remaining supervisors

reported that the person-rem estimate determined by the ALARA group

appeared appropriate. In general, the ALARA group set the annual

goal based on their estimates and there was very little input from

the plant staff supervisors to further reduce exposures.

The licensee exceeded its 1988 person-rem goal by approximately four

l person-rem. The licensee's 1988 ALARA goal of 552 person-rem was the

1988 person-rem estimate. While the licensee demonstrated an ability

to accurately project work and implement ALARA techniques to maintain

personnel exposures ALARA, the input from section supervisors on

, methods to further reduce exposures was minimal. However, the 278

l person-rem totals per unit were low for a facility having portions of

j two refueling outages during the year.

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The inspector attended an outage planning meeting which included key

licensee staff personnel, representatives from Turkey Point, and

corporate staff personnel. The meeting agenda included an open

discussion on lessons learned during the Unit 1 refueling outage and

plans for the upcoming refueling outage. Discussion topics included

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improving worker efficiency, use of mockup . training equipment,

preparation of equipment, improved communications, shielding,

limitations on overtime, training, and exposure-reduction activities.

The inspector observed a free exchange of information in a spirit of'

cooperation to improve work objectives.

The inspector reviewed the following licensee procedures.

ALARA Manual, Revision 3

Maintenance Management Procedure 1.9, CNS ALARA Planning, dited

July 21, 1988

CNS Directive 3.8.1 (TS) ALARA Program, dated August 21, 1988

No violations or deviations were identified.

b. Provisions

Through interviews with licensee representatives the . inspector i

determined that the licensee had established resources to support the '

outage. such as protective clothing, respirators, radiation warning

signs, etc. and had the ability to borrow supplies or equipment from

the utility's other nuclear facilities.

No violations or deviations were identified. .i

c. Training and Qualifications of Vendor Health Physics Technicians  !

TS 6.3 requires that each member of the facility staff meet or exceed

the minimum qualifications of ANSI N18.1-1977 for comparable i

positions, except for the Radiation Protection Manager, who shall

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meet or exceed the qualifications in Regulatory Guide 1.8,

September 1975.

TS 6.4.1 states that a retraining and replacement training program

for the facility staff shall be in accordance with ANSI N18.1-1971.

Paragraph 5.5 of ANSI N18.1 states that a training program shall be

established which maintains the proficiency of the operating

organization through periodic training exercises, instruction

periods, and reviews.

The inspector reviewed plant procedure HP/0/B/1000/19, Vendor Health

Physics Technician Training / Qualification, Revision 0. The inspector

determined that the procedure provides specific guidance for

evaluating the previous work experience of vendor HP technicians in

order to comply with the ANSI N18.1-1971 requirements. The procedure

also specifies the training requirements necessary to meet the

requirements of TS 6.4.1.

No' violations or deviations were identified.

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4. High Radiation Area Control Event-

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 signs bearing the radiation caution symbol and '

the words: CAUTION HIGH . RADI ATION AREA. A "high radiation area" is

defined in 10 CFR 20.202(b)(3), as any area, accessible to personnel, in

which there exists radiation, 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.

TS 6.12 requires that, for individual high radiation areas accessible to

personnel:with radiation levels of greater than 100 mR/hr that are located

within large areas, such as pressurized water reactor (PWR) containment,

where no enclosure 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.

NRC Information Notice (IN) No. 88-79: Misuse of Flashing Lights for High

Radiation Area Controls, was issued on October 7,1988. The Notice was

issued to all holders of operating licenses for nuclear power reactors.

The purpose of the Notice was to alert addressees to problems involving

misuse of flashing lights .for high radiation controls. The Notice

discussed five events involving improper access control of high radiation

areas. As discussed in the Notice, inappropriate use of such access

controls could lead to potentially significant, inadvertent, radiation  ;

exposures. Additionally, the Notice stated that it was apparent that

plant workers and supervisors did not fully understand the TS requirements

for high radiation access control.

During the inspection the inspector determined that on December 16, 1988,

two employees apparently entered a high radiation area unknowingly. One

of the two employees was assigned to the Catawba mechanical maintenance

staff and the other was a construction maintenance department (CMD)

employee based at the Oconee facility on site to support the Unit 1

outage.

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The inspector reviewed the HP Investigation Data sheet which described the

, event and the written statement of the event prepared by the Catawba

I worker. According to the worker, the employees entered lower containment

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after reviewing RWP No.88-919 and after discussing their work with a HP

representative. The two employees were going to perform preventive

maintenance (PM) on several limitorque operators.

According to the worker's statement, he asked the HP technician if a

respirator would be required for entry and was told that respirators would

not be required for the planned work. The workers checked in with the HP

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rover for permission to enter lower containment and were told to proceed.

The- employees climbed down a ladder into lower containment to work on

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their first valve. After completing- work on the first valve the workers ,

crossed over an airduct and up some scaffolding to the second limitorque j

operator. As the men began their paperwork, they were interrupted by HP  :

personnel monitoring the B and C steam generator platform and told that

l they were in a respirator required area and a high radiation area. The HP

technician told the men to exit the platform area which had a flashing

yellow light. The workers exited containment, were surveyed, and found to

be' free of external contamination. One worker received only 10 mrem whole

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body exposure while the second worker received 30 mrem whole body exposure

i for the entry. An air sample taken on the platform did not indicate any

airborne radioactive material .on the steam generator platform.

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The Catawba worker reported in his write-up of the event that they had not

crossed any identified rope or signs in getting to the platform from

above. The worker also stated that he was unaware of the significance of

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a flashing yellow light. The HP Investigation Data sheet also documented

that the licensee workers had entered the platform area from above and

that the workers did not know the significance of the flashing yellow

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light.

The.immediate steps taken to prevent recurrence of this type of event was

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to post the access taken by the workers as a high radiation area. The j

l long-term steps taken to prevent recurrence was to proceduralize the i

posting of the area. The inspector determined that the dose rate on the  !

platform was 500 mrem per hour (mr/hr) beta and 500 mr/hr gamma at the

cold leg side of the generator. The dose rate was approximately 35 mr/hr

four feet from the manway. The gamma dose rate twelve inches from the

manway was 300 mr/hr gamma.

Through interviews with the General Employee Training (GET) supervisor,

the inspector determined that the Catawba worker had taken bypass training

for the last four years and that the use and meaning of yellow flashing

[ warning lights was not included in the bypass training. The inspector

contacted the resident inspector at Oconee and determined that, for the

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CMD employee based at Oconee, the bypass training there also did not

include training on the use and significance of flashing yellow lights.

l Failure of the licensee to provide adequate training for employees

concerning the significance of flashing yellow lights and failure of the

licensee to post accessible areas of a high radiation area in accordance

with the requirements of 10 CFR 20.203(c)(1) are examples of a violation

of NRC requirements of 10 CFR 19.12 requiring the licensee to provide

information and instructions to workers (50-413, 414/89-02-02). This

violation is similar to a violation concerning training cited in a Notice

of Violation issued September 16, 1988, and could reasonably be expected

to have been prevented by previous corrective action.

0ne violation was identified.

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5. Licensee Action on Previous Enforcement Matters (92702)

L (0 pen) Violation 87-31-02: Failure to. adhere to radiological control

! procedures for personnel contamination monitoring and completion of daily

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dose. cards. The item will remain open since previous implementation of

L licensee corrective actions had not been adequate. . This was exemplified

L by a licensee' audit conducted in December 1988, which reported findings

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concerning -persons exiting the RCA from areas that were not normal exit

points, - hand held -items not properly surveyed, dose cards not being

completed for each entry and exit portal, and a contract HP technician

reaching in a RCZ and performing work without being dressed in accordance

with the RWP.

6. Exit' Interview

a. Inspector Comments

The inspection included a review of selected QA Surveillance, Outage

Planning and the ALARA program for control of radiation exposures.

Through review of representative records and discussions with

licensee representatives the inspector reviewed the licensee's

planning, preparations, and management support for implementing the

radiation protection program during outages.

The inspector discussed staffing levels for the outage and

determined that due to budget restraints the licensee had

completed the Unit 1 outage with fewer HP vendor technicians

than previously utilized. Licensee representatives reported

that adequate radiation protection controls were maintained even

with the reduced staff during the outage.

The inspector reviewed licensee's utilization of special

training including use of mockup training.

The inspector discussed the licensee's methods for ensuring

adequate supplies were available to support outage activities.

The inspector reviewed selected ALARA work packages and

determined that the licensee was taking steps to reduce

exposures by clearly defining job sequences and taking measures

to improve worker efficiency and lowering personnel exposures.

The inspector reviewed selected documented which demonstrated

that numerous ALARA pre-job planning and post job meetings were

taking place to ensure that persons were adequately prepared for

upcoming work and methods for improving the tasks were being .

evaluated. )

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The inspector discussed management support for the radiation l

protection program including the purchase of additional

personnel monitors (hand and foot) which were installed and in

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use. Whole Body Friskers had been purchased and the licensee

had initiated the installation of whole body friskers during the

inspection which should enhance personnel monitoring

capabilities. .,

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The inspector. reviewed the licensee's GET program and determined

that the instructors were adequately qualified and that lesson ,

plans were well documented. The inspector determined that the ,

l.icensee could provide the general employee training during the

peak periods prior to outage start dates.

The inspector determined that the licensee had an adequate training

program for vendor HP technicians. i

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b. Inspection Findings  !

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The inspector discussed violation 50-413, 414/87-31-02 issued

October 19, 1987, for failure to adhere to radiological control

procedures for personnel contamination monitoring and completion of

daily dose cards. The item will remain open since previous

implementation of licensee corrective actions had not been

sufficient.

The inspector stated that procedure violations in personnel

monitoring had been documented in the recent radiation protection

inspections. The previously identified violations and those

documented in the licensee's audit report will be reviewed by

Region 11 management for the need to consider additional enforcement ,

actions. The item was left as an unresolved item (URI)*. j

(

Upon review by Region II staff, the licensee's failure to take timely  !

corrective actions of radiological protection violations to preclude j

recurrence was identified as a violation of 10 CFR 50, Appendix B, I

Criterion XVI 50-413, 414/89-02-01 (Paragraph 2.c).

During the inspection, the inspector determined that on December 16,

1988, two licensee employees had unknowingly entered a respirator and

high radiation area established for steam generator work. The area

was monitored by a video system and HP personnel took action to

remove the employees from the area. The inspector reviewed the

radiological investigation sheet and the written account of the

event. According to one of the employees they had not crossed any

high radiation or respirator required boundaries until approached by

HP personnel. The employees had noticed a flashing yellow light but

claimed that they did not know the significance of the light. The

inspector determined that the employees did not receive any internal .

contamination, external contamination, or significant external I

exposure. The inspector stated that there appeared to be a violation

• Unresolved items are matters about which more information is required to

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determine whether they are acceptable or may involve violations or deviations.

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for inadequate GET since neither employee claimed to know the

. significance of flashing yellow lights and/or failure of the licensee

to adequately post a high radiation area. The inspector stated that

the event would be discussed with Region 11 staff following the

inspection.

l The NRC has determined that there were two ' violations; one for

failure to adequately post a high radiation area in accordance with

the requirements of 10 CFR 2.203(c)(1) and one for failure to provide

adequate training for individuals who work in or frequent a

restricted area. The licensee did not identify as proprietary any of

the material provided to or reviewed by the inspector during this

inspection. The inspector expressed his appreciation for the staff

cooperation during the conduct of the inspection.

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