IR 05000317/1997003

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/97-03 & 50-318/97-03

ML20217Q076
Person / Time
Site:	Calvert Cliffs
Issue date:	08/15/1997
From:	Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
50-317-97-03, 50-317-97-3, 50-318-97-03, 50-318-97-3, NUDOCS 9708290139
Download: ML20217Q076 (2)

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August 15, 1997 Mr. Charles Vice President . Nucleat Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657 4702 SUBJECT: NRC INSPECTION REPORT NOS. 50 317/97 03 AND 50 318/97 03 AND NOTICE OF VIOLATION

Dear Mr. Cruse:

This letter refers to your July 31,1997, correspondence in response to our July 1,1997, letter.

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 program.

We appreciate your cooperation.

Sincerely, Original Signed by:

Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects Docket Nos. 50 317 50 318 cc:

T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)

R. McLean, Administrator, Nuclear Evaluations J. Walter, Engineering Division, Public Service Commission of Maryland cc w/ copy of Licensee's Mosponse Letter:

K. Burger, Esquire, Maryland People's Counsel R. Ochs, Maryland Safe Energy Corilition State of Maryland (2)

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hh I LOFFICIAL RECORD COPY

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Mr. Charles Distribution w/ copy of Licensee's Response Letter: f Rl EDO Coordinator S. Stewart Calvert Cliffs A. Dromerick, NRR L. Doorflein , DRP S. Adams,DRP R. Junod, DRP M. Campion, Al Nuclear Safety Inforrnation Center (NSIC)

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PUBLIC Region i Docket Room (with concurrences) ' ':

Inspection Program Branch, NRR (IPAS)

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z DOCUMENT NAME: A:\RL970303.CC-

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To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure "E" =

C:py with attachment / enclosure "N" = No copy OFFICE Rl/DRP ,

Rl/DRP NAME SAdams e p'flh LDoerfleir\y1/d .

DATE 08hv/97 i 08/6/97 OFFICIAL RECORD COPY ,

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On ARI a.h II. OntW limitimore Gas and Electric Company Vice Presiden: Cab ett Clifh Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway i Lusby Maryland 20657

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410 493-4435

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July 31,1997 U. S. Nuclear Regulatory Commission Washington,DC 20555 NITENTION: Document Control Desk )

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. SUllJECT: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & $0 318

Beply to a Notice of Vlointion .- Inspection. Report Nos. 50 317(318V97.03 ,

I ItEFElli:NCE: (a) I etter from hir, l. T. Doerueln (NRC) to hit. C. I (IlGE), dated  :

July 1, 1997, NRC Region 1 Integrated Inspection Report l Nos,50-317/97 03 and 50 318/97 03 and Notice of Violation

In response to Reference (a), Attachment (1) details our response to the cited violation concerning documentation of problems and corrective actions in our corrective actions process.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours,

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CilC/DWhi/bjd j

Attachment ec: R. S. Fleishman, Esquire Resident inspector, NRC J. E. Silberg. Esquire R. I hiclean, DNR A. W. Dromerick, NRC J. ii. Walter, PSC Director, Project Directorate I 1, NRC L T. Doernein, NRC 11. J. hiiller, NRC

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NITACllMLNT (1)  !

NOTICE OF VIOLATION 50-317(318)/97 03-01 MULTIPI E IWAMPLES OF FAILURE TO DOCUMENT AND REPORT TO MANAGEMENT SIGNIFICANT CONDITj0NS AIWERSE TO QUALITY

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Notice of Violation 50 317/97 03 01 and 50 318/97 03 01 describes a non conformance concerning failures to document prcblems and corrective actions in our corrotive actions process. De Notice of Violation states, in part, that:

' As of Afay 20,1997, hsue reports urre not initiated, the cause of the condition and he corrective action taken had not been documented and reports had not bcsn made to managementfor the following significant conditions ach crse to quality:

1. On Afarch 13, technicians responded to apersonnel contamination. The decontamination effort um not done in accordance with radiation sqfetyprocedure RSP 1 107.

2. On April 13, three Cobalt-60 sources urre returned to Cahrrt Cli[fs by a vendor as a e

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limited quantity ahipment. The receipt survey showed up to 1 millirem per hour on contact, u hlch is greater than limi ed quantity.

3. On April S. BGE hientified that personnel were changing alarming dostmeter calibration setpoints in thefield One reason uns that the radiation safetyprocedure RSP 1 129 um not beingfollourd I, IEASON FQ1LIIHLYlOIA11DN Interdepartmental Procedure Ql-2100, " Issue Reponing and Assessment," requires that issue Reports be generated for conditions adverse to quality identiDed by site personnel. The procedure dennes the Gold Card System as "a process used . . . to identify and track the proper use, or misuse of low level management tools which contribute to event free operation at Calven Cliffs." This Notice of Violation involves several instances in which Gold Cards were used in lieu of Issue Reports by Radiation Safety Section personnel to document conditions adverse to quality. As a result, although some corrective actions were taken in most instances, there was no interdisciplinary review, station trending, or elocumentation and verincation of the corrective actions for these issues.

The Gold Card process was initiated in Operations in 1994 as a tool for identifying low level challenges to event-free operation. Plant Management has found the Gold Card process a useful self assessment tool and the use of this process was extended to Radiation Safety in late 1995. At the time this violation was identined Gold Cards had been in use in Radiation Safety for approximately a year and a half.

%ere was some misunderstanding concerning their use and the relationship between the Gold Card and issue Report systems. There was a widespread belief among Radiation Safety Section workers and supervision that Gold Cards were an adequate means for identifying issues. Since Gold Cards are reviewed by supervisors, it was believed that they would be elevated to issue Reports, when necessary, by the supervisor during his review, in the cases discussed in this Violation, the workers documenting the issues believed that Gold Cards were an appropriate means of documenting the issues and the reviewing supervisors failed to recognize that issue Reports were required.

The cause of this event was less than adequate training of Radiation Safety personnel and supervision on the distinction between Gold Cards and Issue Reports combined with less than adequate oversight of the Gold Card Program by Radiation Safety management. Introductory training was provided in

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, A'ITACllMENT (1)

NOTICE OF VIOLATION 50 317(318)/97-03-01 MULTIPLE EXAMPLES OF FAILURE TO DOCUMENT AND REPORT TO

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November 1995 when the Gold Card Program was initiated in Radiation Safety. It did not discuss the relationship between the Gold Card and issue Report systems. Contractor training in preparation for the 1997 Unit 2 Refueling Outage dwelled on Gold Card usage and did not place as much emphasis on the need for issue Reports to document conditions adverse to quality. This contributed to the impression among Contractor Radiation Safety Section workers that Gold Cards were the means for identifying conditions adverse to quality.

11. CORRECTIVE STEPS TAKEN AND RESULTS ACIIIFVED Radiation Safety Section personnel reviewed all Gold Cards issued since the beginning of the 1997 Unit 2 Refueling Outage.1hree additional issue Reports were generated as a result of this review.

All Radiation Safety Section personnel have been provided awareness training on this issue and on management's expectations concerning the documentation of deficiencies and non conformances via Issue Reports vice Gold Cards. The distinction between the two has been re emphasired. All newly issued Gold Cards are being reviewed at Radiation Safety Section staff meetings to ensure that issue Reports are generated, if warranted. This practice will continue until such time that the General Supervisor Radiation Safety is satisfied that the issue Report threshold is adequately understood by Radiation Safety supervision and personnel or Gold Card Program changes are implemented.

Ill. C010tECTIVE STEPS WillCll WILL llE TAKEN TO AVOID FURTIIER

.Y101AT10NS An efrort is currently undenvay to review Gold Card use on site and ensure that conditions adverse to quality noted via Gold Card are entered into the corrective action process.

IV. DATE WlIEN FUI L COh1PLIANCE WILL llE AClIIEVED l'ull compliance was achieved on July 18,1997, when all issues identified in this Notice of Violation and the subsequent review were correctly documented on issue Reports.

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