IR 05000317/1989010

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/89-10 & 50-318/89-10

ML20248B930
Person / Time
Site:	Calvert Cliffs
Issue date:	08/01/1989
From:	Bellamy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Creel G BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 8908090374
Download: ML20248B930 (2)

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AUG 011993 1 .

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Docket No. 50-317gl$ -

-Baltimore Gas and Electric Company ATTN: Mr. George C. Creel Vice President Nuclear Energy Calvert Cliffs Nuclear Power Plant MD Rts 2 & 4, P.O. Box 1535'

Lusby, Maryland ~ '20657 Gentlemen:

3W Subject: Itspection 50-318/89-10 This refers to your letter dated July 7,19.89, in response to our letter dated June 8, 198 Thank you.for informing us of the corrective and preventive actions documented in .your letter. These actions will be examined during a future inspect' ion of your licensed progra Your cooper 6 tion with us is appreciate

Sincerely, Odinct Signed By*

km!d R. Belber/ -

Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeauar : Branch Division of Radiation Safety and Safeguards cc .w/wr4:

?d. J. Lippold, General Supervisor, Technical Services Engineering T. Magette, Administrator, Nuclear Evaluations Public Document Room (PDR)

Local Public Document Room (LPDR)

' Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of Maryland (2)

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0FFICIAL RECORD COPY RL BG&EC 89-10 - 0001. \(

l 07/24/89 890809o374 PDR 890801 ADOCK 05000317 3Plas h

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, . . . l-Baltimore Gas and 2  !

Electric Company 1 AUG 01 1989 bec w/ encl: '

Region I Docket Room (with concurrences)

Management. Assistant, DRMA (w/o enc 1)

J. Wiggins, DRP L. Tripp, DRP D.' Limroth, DRP

S. McNeil, NRR PA0 (14) SALP Reports Only {"

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RI:DRSS RSS RI:DRSS Lo h/mk Pa ciak Bellamy 07 /89 03/{/89 Og/\ /89 0FFICIAL RECORD COPY RL BG&EC 89-10 - 0002. /24/89

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p = -i BALTIMORE j GAS AND.:

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CHARLES CENTER P.O. BOX 1475. BALTIMORE, MARYLAND 21203 Gromoc C. CatcL VACC PRESIDENT NUCLtan CNtnGV-n oo n e.. n July 7,1989

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U. S. Nuclear Regulatory Commission Washington, DC 20555-ATTENTION: Document Control Desk SUBJECT: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & $0-318 Reply' to Notice of Violation (Inspection Report Nos. 50-317/89-10; '

50-318/89-10)

REFERENCE: (a) Letter from M R. Bellamy (NRC) to M G. C. Creel

. (BG&E), dated June 8,1989, same subject Gentlemen:

'As requested in Reference (a), we are providing the following response to the subject Notice of Violation. Two violations were combined into one Severity' Level IV viohtion against our Radiological Pro'o son Progra The violation identified two deficiencies within the Radiological Protection Progra Failure to review radiological surveys; and, Failure to perform ALARA Field Services installation inspection . Corrective Steos Taken and Results Achieved

~ The inspector identified four Special Work Permit (SWP) packages, Nos.89-829, 89-2303, 89-2305, and 89-2309, where radiological surveys were

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not ' reviewed properly by the Supervisor Radiation Control Operations (or his de ignee) for completeness and/or for correct and appropriate dat This is contrary to the requirements set forth in Radiation Safety Procedure (RSP) 1-101, " Radiological Surveys," section 3. Immediately upon notification (May 10, 1989), an in-depth audit was initiated to review all outage SWP packages to determine procedural L

compliance (audit was completed May 16, 1989). Additional examples of similar deficiencies were found. In addition, the AGS-RCS met with all Radiation Safety Supervisors and Radiation Safety Technicians to clarify l

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July 7. 1989 '

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l; and emphasize strict procedural compliance in the performance and ,eview of radiological surveys. This was documented via a Calvert Cliffr Memorandum (CCTM 89-RS-35) dated May 9,1989. Subsequently, the GS-RS personally met with the . Radiation Safety Supervisors to r .inforce the fact that they and their technicians are personally accountable for . conformance to procedure . The inspector identified . three - SWP packages, Nos. 89-2038, 89-2501, and 89-2503, where failures to perform ALARAt Field Services Installation inspections at the frequency stated on the ALARA Field Services Worksheet (RSP l-202-1) were evident. This is. contrary. to the requirements set forth in RSP l-202, "ALARA Field Services," section 6.1.3 and Immediately' upon notification (May 10, 1989), an audit of all outage SWP packages requiring ALARA Field Services installation inspections was conducted with emphasis placed on field . installation inspection frequencies (audit . completed May 15, 1989). Additional examples of . similar deficien-cies were' found. In addition, an interim inspection tracking mechanism was put in place to ensure / enhance procedural compliance for ongoing tasks (effective May 22, 1989) until a formal tracking mechanism can ~ be established within the procedur . ' Corrective' Steos Which Will be Taken to Avoid Further Violations The outage SWP audit highlighted weaknesses with two RSPs that govern the Radiological Survey Program. Specifically, RSP l-101, " Radiological Survey Programs," prmides vague direction when requiring certain surveys

~to ~ be conducted (e.g., beta exposure rates, ' alpha loose surface ' contamina-tion determinations, and ' large area smear determinations), and in the administration and use of Job Coverage Data /Re-survey Records (JCD/RR).

In addition, RSP l-106, "Special Work Permit Administration," currently does not formally include the JCD/RR, nor d6es it allow flexibility in the assignment of surveys based on changes in job statu Both of these procedures, RSP l-101 and 1-106, are currently being revised to address / resolve these deficiencie The RSP that governs ALARA Field Services installation inspections, RSP l-202, "ALARA Field Services," currently does not provide a formal tracking mechanism to ensure that all required inspections are performe This procedure currently is being revised to provide a formal tracking mechanism for ALARA Field Services installation inspection . Dale When Fuji Comoliance Will be Achieved Procedural revisions for RSPs 1-101, " Radiological Surveys," l-106, "Special Work Permit Administration," and 1-202, "ALARA Field Services" are currently being performed and will be implemented by July 31, 1989.

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.' Document Control Desk

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July 7.-'1989

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Should you have any ' further questions regarding ; this matter, we 'will be pleased to discuss them with yo I Very truly yours, s

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GCC/ PSF / dim i

cc: D. A. Brune, Esquire l J. E. Silberg, i Esquire

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R. A.Capra,NRC S. A.McNeil,NRC W. T. Russell, NRC H. Eichenholz/V.. L. Pritchett, NRC T. Magette, DNR

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