IR 05000317/1990032
| ML20029A959 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/22/1991 |
| From: | Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9103050152 | |
| Download: ML20029A959 (2) | |
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Docket No. 50-317
50-318 I
Baltimore Gas and Electric Company A1TN: 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:
Subject:
Inspection No. 50-317/90-32; 50-318/90-32 This refers to your letter dated January 17, 1991, in response to our letter
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dated December 18, 1990.
Thank you for informing r, of the corrective and preventive actions documented in your letter. These at. cions will be examined during < future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely
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Occrt! Es,n d Dy-Jmnes H. Joynar James H. Joyner, Chief Facilities Radiological Safety and $sfeguards Branch Division of Radiation Safety and Safeguards CC:
R. McLean, Administrator, Nuclear Evaluations J. Walter, Engineering Division, Public Service Commission of Maryland G. Adams, licensing (CCNPP)
K. Burger, Esquire, Maryland People's Counsel P. Birnie, Maryland Safe Energy Coalition Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K, Abraham, PA0 (22) SALP Reports and (2) All Inspection Reports l
Public Document Room (PDR)
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Nuclear Safety Information Center (NSIC)
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NRC Resident Inspector
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State of Maryland (2)
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0FFICIAL RECORD COPY RL CALVERT 90-32 - 0001.0.0
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9103050152 910222 02/08/91 l-PDR ADOCK 0D000317 l. 1
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[3 AL71MORE CAS AND !
ELECTRIC CHARLES CENTER e P.O DOX 1475 e BALTIMORE. M ARYLAND 21203 1475 Gtostor C Cnttu
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January 17,1991 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk i
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2: Docket Nos. 50 317 & $0 318 NRC inspection Report Nos. 5011"W132 and 50 31RM132 Gentlemen:
The subject inspection report contained a Notice of Violation regarding three instances of plant personnel entering High Radiation Areas without dose rate meters. Our response to the Notice of Violation is provided in Attachmen;(1).
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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GCC/JV/bjd Attachment cc:
D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC L E. Nicholson, NRC R. I. McLean, DNR cyg y-:, 7 -i~7b'f
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l NITAGMEFI Ol
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NRC INSpECTIDN l!EPORT NOS. 50017!904 LAND $0418!9042 DESCRIPTION AND CAUSE Of Viol ATION On January 17,1990, during a routine Radiation Safety Technician (RST) inspection, two contractor personnel were found inside a posted liigh Radiation Area (IIRA) without a continuously monitoring suncy iratrument (dose rate rneter). The contractors had observed other contractors routinely going in and out of the posted IIRA for several days and did not notice them carrying dose rate meters. The two contractors had not Rceived any dose on previous entries into this particular IIRA.
On February 6,1990, an RST found a plant operator exiting a posted !!RA without a dose rate meter. The operator had entered and surveyed the same area 30 minutes earlier and determined it i
was not an llRA. The operator had his hands full on the second trip. }!c therefore decided to proceed into the area without the meter based on his n.L.cy f rom the previous entry.
On June 13,19% an RST found two contractor personnel in a posted HRA without a dose rate meter. The contractors incorrectly assumed that their RST had logged thern into the llRA with the Special Control Point Watch (SCPW) and had gone into the } IRA ahead of them. They crossed the radiological IIRA boundary assuming the RST had taken care of their radiological requirements before entering the IIRA The causes of these events were inattention to detail, plus a lack of uncern for work controls and radiological hazards associated with IIRAs. In the Erst event, the two contractors believed that dose rate meters were not required in an lira based on their perceptions that other personnel were entering the area without dose rate meters. The operator in the second event entered an IIRA without a dose rate meter even though he had seen and understood the llRA posting requirements.
His indisidual made a conscious decision to enter the llRA based on the results of his radiation survey 30 minutes earlict. The contractors in the third event incorrectly assumed that they had been logged into the !!RA and that the RST would ensure appropriate radiological controls were met for entering the IIRA.
Two lluman Performance Evaluation System investigations were performed at the direction of the Plant Manager, The first was initiated after the second event occurred. The second was initiated after the third event occuned. These evaluations identi6cd the human factor contributors to these violations of HRA controls and provided recommenced corrective actions.
CORRECTIVE ACrlONS Til AT libVE IlEEN TAKEN AND Tile RESULTS ACllllNED The personnelinvolved were immediately removed from the llRA.
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The training qualification records of the personnelinvolved were evaluated. It was veri 6cd
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that each individual had been previously trained concerning the plant speci6c requirements for entering HRAs.
Appropriate disciplinary action was administered in each case.
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Because of the repeat nature of these events and indications of lack of concern and
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inattention to detail regarding entering IIRAs, Plant Management directed that a site wide safety break be held to discuss the Radiation Control violations. This immediate corrective action was taken to re emphasize management expectations regarding strictly following
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A'ITACllMENT (1)
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NRC INSPECTION REPORT NOS. 50 317/90 32 AND 50 31ft!90 32 Radiation Control procedures and policies. This issue was also ernphasized to all plant personnel sia a hanc out memorandum distributed at the facility exits.
Plant Management has continued to emphasize the importance of attention to detail and maintaining a questioiiing attitude to all personnel through a variety of mediums, including Quarterly Communications Meetings, the Calvert Cliffs Newsletter 'Calvert Clips * and the
- Our Mutual Obligations * statement. Strict procedural adherence has been the cornerstone of our Performance Improvement Plan and continues to be emphasized on a site wide basis.
The placement of IIRA boundaries has been evaluated and improved.
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The events have been incorporated into the * Industry Events * section of our General
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Orientation Training (GOT) Initial and 1991 requalification training program tor the next training cycle.
GOT programs have been changed to include mockup training for all contractor workers.
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Work practices and procedures for RSTs have been standardized to require each worker in
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an llRA log himself into the access log for that area. RSTs are no longer allowed to log other personnel into IIRAs.
A * Hands Free * portable survey instrument has been placed in senice. This instrument will
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be available for instances where an individual entering an llRA has both hands full or occupied.
CORRECTIVE ACTIONS Til AT Will,ilE TAKl:N TO AVOID FURTilER VIOL ATIONS A training video tape is currently being created to sisually demonstrate the requirements for entering HRAs.
We feel that these actions, combined with the strength of our existing Radiation Safety training program, and continued plant management emphasis on attention to detail, will further reduce the potential for future violations in this area.
DATE WilEN FULL COMPI,IANCE WAS ACillEVED Full compliance was achieved for each respective event when the personnel involved were immediately removed from the HRAs.
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