IR 05000317/1985017

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/85-17 & 50-318/85-15.Violations Remain as Previously Issued Based on Lack of Sufficient Evidence to Refute

ML20138B480
Person / Time
Site:	Calvert Cliffs
Issue date:	12/09/1985
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Poindexter C BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 8512120307
Download: ML20138B480 (2)

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DEC 0 01985 Docket Nos. 50-317 License Nos. OpR-53 50-318 DPR-69 Baltimore Gas and Electric Company ATTN: Mr. Chris H. Poindexter Vice President, Engineering and Construction P. O. Box 1475 Baltimore, Maryland 21203 Gentlemen:

Subject: Inspection Report Nos. 50-317/85-17 and 50-318/85-15 This refers to your letter dated August 30, 1985, in response to our letter dated July 12, 198 Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed progra We have reviewed your request that we reconsider the issuance of the items of noncompliance. The violations will remain as previously issued because you have not provided sufficient evidence to refute the Should you continue to want the NRC to reconsider the Notice of Violation, any information provided should be submitted under oath by persons with relevant, first hand knowledge of the facts you feel should form the basis for with-drawing the Notice of Violation, otherwise no further response is required at this tim Your cooperation with us is appreciate

Sincerely, O'lRinnt w .,a NI Thomas T. Martin, Directt r Division of Radiation Safety and Safeguards 0512120307 851209 PDR ADOCK 05000317 O PDR -

0FFICIAL RECORD COPY RL CC 85-17/15 - 0001. i 12/05/85 b

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• Baltimore Gas and Electric Company 2 cc:

R. M. Douglass, Manager, Quality Assurance L. B. Russell, Plant Superintendent Thomas Magette, Administrator, Nuclear Evaluations R. C. L. Olson, Principal Engineer J. A. Tiernan, Manager, Nuclear Power R. E. Denton, General Supervisor, Training and Technical Services Public Document Room (POR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of Maryland (2)

A. E. Lundvall, Jr., Vice President Supply bcc:

Region I Docket Room (with concurrences)

Senior Operations Officer DRP Section Chief M. McBride, RI, Pilgrim T. Kenny, SRI, Salem D. Jaf fe, LPM, NRR

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p BALTIMORE GAS AND ELECTRIC CHARLES CENTER . P.O. BOX 1475. BALTIMORE, MARYLAND 21203 CHmis H. PosNDEXTER WCE Pets.otNT c~omEE.~a ~o co~srwoo~ August 30,1985

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U. S. Nuclear Regulatory Commission Docket No Region !30-318 631 Park Avenue License No DPR-53 King of Prussia, PA 19406 DPR-69 ATTENTION: Mr. Thomas T. Martin, Director Division of Radiation Safety & Safeguards -

Gentlemen:

This refers to Inspection Report 50-317/35-17, 50-313/35-15; which identified two items of apparent noncompliance with NRC regulations and five allegation We have conducted a thorough review of the inspection results and our related radiation safety practice Enclosure (1) to this letter is a wri' ten statement in reply to those allegations and apparent items of noncompliance noted in your letter of July 12,198 Based on the information provided in Enclosure (1), we request you reconsider the issuance of the subject items of noncompliance. Should you have further questions regarding this reply, we will be pleased to discuss them with yo Very truly yours,

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AEL/SRC/gla

• t Enclosure cc: D. A. Brune, Esquire G. F. Trowbridge, Esquire D. H. Jaffe, NRC T. Foley, NRC

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ENCLOSURE (1)

REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/85-17; 50-318/85-15 ITEM A A review of an Individual's radiation exposure history records prior to allowing him to receive radiation exposures, as authorized by 10 CFR 20.101(b), is a standard business practice at the Calvert Cliffs Nuclear Power Plant (Radiation Safety Procedure RSP 3-102). This practice was followed when the individual referred to in this report originally reported to our Dosimetry Unit for processing on April 6,1982, and prior to being assigned work in radiologically controlled areas on site. This individual stated on his radiological control information form on April 6,1982, that he was previously employed by the U. S. Army, which had a record of his previous occupational radiation exposure. Our Dosimetry Unit made two written requests on April 13, 1982, to obtain this history. One request was sent to the U. S. Army, using the address provided by the individual, and the second request was sent to the U. S. Navy, in case the individual had been stationed at a Navy facilit During the period of April 13, 1982, to December 17,1982, the individual's supervisor, on three occasions, requested that he be allowed to receive radiation exposure as authorized by 10 CFR 20.101(b). These requests were disapproved because documentation of the individual's past radiation exposure history while in the U. S. Army was not complete at that time. Later in September 1983 and April 1984, the individual's supervisor requested that this individual be allowed to receive radiation exposures as authorized by 10 CFR 20.101(b). Again, in accordance with our standard program, the Dosimetry Unit performed the required record checks on the individual's radiation history and on these occasions possessed omplete documentation of past radiation exposure history. This documentation was supported by quarterly exposure increase authorization documents for the fourth quarter 1983 and second quarter 1984 periods. Also, the individual's Form NRC-4 showed zero exposure. In addition, calculations of permissible dose to whole body, shown at the bottom of the Form NRCw, were performed and supported the exposure authorization. The customary record verifications, in September 1983 and April 1984, were performed by two Dosimetry Technicians who have a reputation for meticulous attention to the details of radiation exposure. Therefore, the past radiation exposure documentation was considered satisfactory for authorization of the September 1983 and April 1984 request .

Meanwhile, in an unrelated Company initiative, a verification of all individual radiation exposure history records (approximately 10,000 records) was being performed by our Dosimetry Unit. This check commenced in the first half of 1984. This verification included the inspection of all documentation required by NRC and Company directive On June 19, 1984, the exposure history record of the subject ir.di/idual was reviewed for verification purposes and documentation on the U. S. Army radiation exposures was identified as missing. Fo!!ow-up actions were taken by the Dosimetry Unit to obtain replacement documentation by written request to the U. S. Army. The Form NRC-4 as mentioned previously had the recorded zeros and calculations of permissible dose lined out, which we suspect was inadvertently and inappropriately made by an unidentified individual at this time, because of the missing documentation. We do not know, however, when changes on this record actually occurre '.

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ENCLOSURE (1)

REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/35-17; 50-313/35-15 The licensee-identified missing documentation, for previous radiation exposure history, was not considered to be a noncompliance with 10 CFR 20.101(b), since the normal course of business in maintaining these records and determining allowed exposure apparently had been followe All other circumstances, as indicated above, demonstrated that such documentation existed in the individual's record prior to approval of increased exposure requested in the fourth calendar quarter 1933 and the second calendar quarter 1934, but that the record was subsequently found to be missin ITEM B ,

As stated in response to item A of the Notice of Violation, noncompliance with 10 CFR 20.101(b) was not considered to have occurred; therefore, the reporting requirements of 10 CFR 20.405 were not considered to be applicable. Admittedly, a licensee-identified noncompliance with to CFR 20.102(cX2) did occur, in that the supportive documentation was lost and not retained and preserved as specified by this provision. The reporting requirements of 10 CFR 20.405 do not include a noncompliance with 10 CFR 20.102(cX2).

To replace the missing documentation, the subject individual was asked in June 1934, to sign another letter authorizing release of his U. 5. Army records, which he refused. He was apparently apprehensive about the radiation exposure he previously received. This apprehension was unwarranted as his radiation exposures were well within regulatory and Company administrative limits, and were commensurate with co-worker exposures. Due to the individual's concerns, the on site Resident NRC Inspector was notified on June 19,1984, by the Company of the situation. Noncompliance with 10 CFR 20.101(b)

was not considered to be an item at issu An evaluation was performed by a staff Health Physicist, to demonstrate that this individual did not receive an overexposure by the use of the 10 CFR 20.101(b) authorized calculation method. This calculation could be used in the future if it were necessary for the individual to receive radiation exposures authorized by 10 CFR 20.101(b). It was not intended to substitute this Form NRC-4 calculation for the missing exposure history documentation that was used to allow the individual to receive exposures in accordance with 10 CFR 20.101(b) and 20.102, for the fourth quarter 1933 and the second calendar quarter 1934 exposur This event is considered to be an isolated occurrence involving one document out of 10,000 exposure records maintained per year, with each exposure record including from 10 to 20 individual documents. This Landling of over 100,000 individual documents, is considered demonstrative of a well-managed, records retention and retreival syste However, to aid in preventing future dccument losses, the dosimetry personnel have been reinstructed in the importance and care of exposure document Additional j administrative controls on access to these documents have been instituted, requiring a i

written request by the employee for c.opies of records of interest, and prohibiting direct access to the original documents. Specific documentation of the results of the records verification is also now require '

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ENCLOSURE (1)

REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/85-17; 50-318/85-15 SUMMARY As stated in response to Item A, noncompliance with 10 CFR 20.101(b) was not considered to have occurred since the normal course of business in maintaining the records and determining allowed exposure apparently had been followed. All other circumstances demonstrated that documentation existed in the individual's record prior to the approval of increased exposure requested in the fourth calendar quarter 1983 and the second calendar quarter 1984. Admittedly, a license-identified noncompliance with 10 CFR 20.102(cX2) did occur, in that the supportive documentation is missing and not retained and preserved as specified by this provisio Because a noncompliance with 10 CFR 20.101(b) was not considered to have occurred, the reporting requirements of 10 CFR 20.405 were not believed to be applicable and, therefore, no noncompliance occurred. Furthermore, the reporting requirements of 10 CFR 20.405 do not include a noncompliance with 10 CFR 20.102(cX2).

RESPONSE TO WORKER ALLEGATIONS

'; Response to the individual's allegation that ". . . the licensee changed his Form NRC4 without his consent. . . ."

We, the Licensee, have been unable to determine specifically who, or in what context, the Form NRC4 was changed. However, we believe that these addition of

"U. S. Army" was inserted based upon further information obtained from the individual which contradicted his initial response of "None." We further believe that the insertion of the zero exposure resulted from obtaining the required information from the U. S. Army by the normal course. We further believe that the striking of the zero exposure was made by an unknown person as the result of a subsequent records verification check. While the manner in which said changes were made may have been inappropriate, the effect of such changes was to the individual's benefi Response to the individual's allegation that ". . . the licensee did not determine his prior occupational exposure history before allowing his exposure to exceed 1,250 mrem per quarter. . . ."

From all indications in our records, we did determine this individual's prior occupational exposure history before allowing his exposure to exceed 1,250 mrem per quarter. This is explained in the response to item A in the Notice of Violatio , Response to the individual's allegation that " . . . the licensee improperly placed a new address and date on a previously assigned release form permitting the licensee to obtain his exposure history . . . ."

The individual signed a total release authorization for this purpose, thereby authorizing its use to obtain exposure information from any sourc . .

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ENCLOSURE (1)

REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/85-17; 50-318/85-15 D. Response to the individual's allegation that ". . . His name was improperly removed from the licensee's computer list of individuals whose exposure should not exceed 1,250 mrem per quarter . . . . "

At the time, all necessary records were on hand to permit the Company to remove the individual's name from the computer list of restricted workers whose exposure should not exceed 1,250 mrem per calendar quarte E. Response to the individual's allegation that " . . . He received a potential exposure in excess of regulatory limits . . . . "

As stated in the response to the Notice of Violation, Item A, it was considered that the individual was authorized to receive exposure in accordance with 10 CFR 20.101(b) and, therefore, an exposure in excess of regulatory limits is not considered to have occurred. As was indicated in the NRC Notice of Violation dated July 12, 1985, the individual's exposure was being controlled to less than three rems per quarte *

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