ML19261A737
| ML19261A737 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/29/1978 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19261A736 | List: |
| References | |
| NUDOCS 7902080074 | |
| Download: ML19261A737 (4) | |
Text
B ALTIMORE G AS AND ELECTRIC COMPANY P.O. B O X 14 7 5 B A LTIM O R E, M A R YL A N D 21203 ARTHUR [. LU N OVALL, J R.
vice p.esionar
- Swees, December 29,1978 U.S. Nuclear Pegulatory Commission Docket Nos.
50-317/50-318 Region I License Nos. DPR-53/DPR-69 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention: George H. Smith, Chief Fuel Facility and ftaterials, Safety Branch Gentlemen:
This refers to your Inspection Report 50-317/78-36; 50-318/78-21, which transmitted items of apparent non-compliance with NRC require-me nts. Enclosure (1) to this letter is a written statement in reply to the items noted in your letter of December 12, 1978.
Should you have further questions regarding this reply, we will be pleased to discuss them with you.
Very truly yours jr.
A. E. Lundy 11, Jr.
Vice President - supply AEL/ETR/ds Enclosure 7902080C91'(
ENCLOSURE (1)
REPLY TO NRC LETTER DATED DECEMBER 12, 1978 NRC INSPECTION REPORT 50-317/78-36; 50-318/78-21 ITEM A RESPONSE To prevent recurrence of this item, Radiation Safety and Chemistry personnel were reinstructed by the Rad-Chem Foreman on September 14,1978 in the requirements and procedures for evaluating concentrations of radioactive ma'.erials in air, in accordance with RCP 3-401, with special enphasis placed on airborne contamination surveillance during refueling and maintenance operation periods.
To evaluate the successfulnass of this instruction, the Plant Health Physicist and the Rad-Chen Foreman perfomed independent random checks to determine whether Special Work Permits were properly prepared and whether require, evaluations of airborne concentrations of radioactive materials were cerio,Md. These checks revealed no procecaral deviation during the Unit 2 Refueling Outage period (September 15 to October 29, 1978); there-fore, the instruction has been considered successful.
Full compliance is considered to have been achieved as of September 14, 1978.
ITEl1 B AND D RESPONSE High Radiation Areas and Transient Hich Radiation Areas were reviewed to detemine possible future preventive measures that may be beneficial in eliminating recurrence of this item.
Based on the occurrence and access frequencies into these areas, automatic door closing devices were installed on the Charging Pump Room's barricade doors on November 18, 1978. A continuing review of barricades for High Radiation Areas will be made to determine whether additional oreventive actions are necessary.
To aid in preventing recurrence of these items, the personnel involved were reinstructed in the importance of following procedural requirements for entrance into High Radiation areas.
In addition, Plant Supervisors are giving this matter their particular attention by discussing the problems associated with radiological procedures violations in order to avoid future recurrence of these items.
Full compliance is considered to have been achieved as of November 8,1978.
~
ENCLOSURE (1) 2 ITEM C RESPONSE Upon notification, the Radiation Safety and Chemistry Group immediately posted the Unit 2 Butler Building with conspicuous signs for a radio-active materials storage area in accordance with 10CFR20.203 and placed locks on the access doors. Technicians were reminded of the requirement of radioactive materials storage areas being posted when the amount of activity stored in this area exceeds 10 tines the quantity of such material specified in Appendix E of 10CFR20.
Full compliance is considered to have been achieved as of October 11, 1978.
OTHER C0te!ENTS This refers to Item 2 of the " Details" section of subject I&E Inspection Report, of which we find disagreement with several of the statements contained therein.
Our procedural requirements for the past two years for acceptance of contracted Health Physics Technicians to supplement the Plant's complement involves a concerted effort to evaluate each technician's experience and training and to determine whether contractural and Technical Specification 6.3 requirements have been met prior to acceptance of the individual by the Radiation Safety and Chemistry Foreman.
At the tine of the subject NRC I&E inspection, a large number of contracted techniciars were in the process of checking-in with Rad-Chem.
The inspector reviewed the qualification of these individuals prior to their acceptance by the Rad-Chem foreman which subsequently caused misleading and incorrect statements to be made in item 2 of the " Details". The inspector was informed of the inappropriateness of his review at that time, indicating to him that the contracted personnel were neither evaluated nor accepted as of that time for service at Calvert Cliffs.
As written in " Details", there are strong indications that Calvert Cliffs personnel planned to accept and utilize contracted technicians who d.d not meet ANSI N18.1-1977 standards; therefore, we would have been in non.
compliance with Technical Specification 6.3.
The statements,
"...the licensee augmented the Radiation Safety Group by contracting the services of about 4C additional Health Physics Technicians.
On September 14, 1978, the inspector reviewed the qualifications of certain of these personnel that were intended to fill responsible positions. Of 38 resumes reviewed, it was noted that only 17 of the individuals had qualifications in accord with ANSI N18.1-1971, Section 4.5.2."
indicated that Calvert Cliffs actually intended to use these individuals as technicians, when in reality no technicians were accepted as of that date.
In addition, the next paragraph in " Details" indicated that NRC
. E '.
ENCLOSURE (1) 3 OTHER COMMENTS (CONTINUED) notified plant personnel of their review findings after which plant personnel reportedly
... indicated that all of the individuals would be re-evaluated and personnel changes would be made as necessary to assure that technicians in responsible positions met the qualifications of ANSI N18.1-1971."
This statement is incorrect, in that, as oreviously stated, the inspector was notified that the contracted personr.el were not accepted as of that time for services at Calvert Cliffs and that these individuals were in the precess of being evaluated for acceptance by the Rad-Chem Foreman.
.