ML19296D219

Forwards Response to NRC 791017 Ltr Re Violations Noted in IE Insp Repts 50-317/79-13 & 50-318/79-10.Corrective Actions:Posting Requirements & Procedure for Radiation Protection Are in Compliance W/Code

ML19296D219
Person / Time
Site:	Calvert Cliffs
Issue date:	11/09/1979
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19296D213	List: ML19296D215 ML19296D219
References
NUDOCS 8003030024
Download: ML19296D219 (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 AN D 21203 AaTMum E. Luw ovALL.JR.

v.c a p.c s.c a m e Sw eest November 9, 1979 U.S. Nuclear Regulatory Commissicn Docket Nos. 50-317 Reaion I 50-318 631 Park Avenue License Nos. DPR-53 King of Prussia, PA 19406 DPR-69 Attention: George H. Smith, Chief Fuel Facility and Materials Safety Branch Gentlemen:

This refers to your Inspection Report 50-317/79-13; 50-318/79-10, which transmitted items of apparent noncompliance with NRC reauire-ments. Enclosure (1) to this letter is a written statement in reoly to the items noted in your letter of October 17, 1979.

Should you have further cuestions regarding this reply, we will be pleased to discuss them with you.

Very truly yours,

)

A. t. Lundvall, Jr.

Vice President-Supply AEL/ RED /gla Enclosure 800303oON'

/.:

• ~ ~

ENCLOSURE (1)

REPLY TO APPENDIX A 0F NRC (IE: REGION 1) LETTER OF OCTOBER 17, 1979 ITEM A The " posting to workers" recuired by 10 CFR 19.11 and noted in your report has been updated to include references to the plant operating licenses and the operating procedures. Additionally, copies of the posting have been conspicuously displaye:d at the entrances to the plant protected area (both guard houses) and adjacent to the Turbine Building elevator and Control Room entrance (in addition, to the location noted in your report). We believe these postings are now in full compliance with the requirements of 10 CFR 19.11.

ITEM B Calvert Cliffs procedures require the delineation of established airborne radio-activity areas by appropriate postina as described in 10 CFR 20.203(d). Posting of the Containment as an Airborne Radioactivity Area is normally accomplished by placing an appropriate sign on the Containment access door during normal operations or at accesses to known airborne radioactivity areas within the Containment during maintenance and/or refueling outages. At the time of subject inspection, the U-2 Containment was in the process of beina closed un in preparation for reactor start-up, and the few remaining individuals in the Containment perfoming preoperational work were provided continuous coverage by Radiation Safety and Chemistry Technicians as described in the appropriate Special Work Permits (SWP). Airborne activity levels in the Containment did not exceed those listed in 10 CFR 20, Appendix B, Table 1, Column 1; therefore, requirements for posting according to 10 CFR 20.203 (d) or to our procedures was not reouired during the time of the NRC Inspector's entry into the Containment.

A plant procedural requirement for posting of the Containment access door delineating the Containment as a Contaminated Area was complied with prior to and during the time the subject inspector made his entry into the Containment for inspection purposes. This sign required that entries into that area were to be made only under Rad-Chem control and according to the Radiation Work Pemit (RWP) or SWP specified for the work process to be performed. The Inspector entered the Containment under SWP 79-467 which by our procedure (RCP 3-605) required the use of a filter resoirator for access to the 10-foot Elevation due to high surface contamination levels existing sporatically throuohout this elevation. RCP 3-605, Section 3.0 states in part:

"3.1 Respiratory equipment shall be work any time that: -----

2 3.1.2 Beta / gar a contamination exceeds 20,000 dpm/100cm in a significant portion of the work area or room and airborne radioactivity is not subsequently evaluated to demonstrate that resciratory equipment is not required or when beta /

2 gama contamination exceeds 150,000 dpm/100cm regardless of airborne radioactivity evaluation."

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These levels were selected by a determination of the relative biological hazards associated with various levels of surface beta-gamma contamination using standard comparisons of contamination levels, their possible intake via the respiratory and gastrointestinal tracts, and the absorbed dose received by the referenced organs from such intakes. Although these levels do not represent an unacceptable biological hazard, under the conditions described in RCP 3 '605, Section 3.1, every effort is maintained to keep contamination levels as low as is readily and reasonable achievable and only when engineering controls and decontamination are impractical or counterproductive will work be allowed to be performed in high contamination areas. A review of our procedures prepared pursuant to 10 CFR 20.103 (c) explains the requirements for wearing respirators in the 10-foot Elevation.

Our survey records have been reviewed and have indicated that the contamination levels on the 10-foot Elevation were in excess of the crocedural requirement which requires the use of a respirator for access to this area. The Inspector, not being familiar with our procedures and requirements, misjudoed the need for respiratory protection based on the contamination level criteron. Records of surface contamination levels on other elevations of the Containment did not reveal any accessible area that had levels requiring respiratory protection.

The statement nade on page 5 of " DETAILS" in your inspection report states:

"No difference of any consequence was indicated in the airborne radioactivity levels and in the floor contamination of the areas toured without resoirators on Acgust 1,1979, as compared to areas toured on August 2,1979, wearing respirators."

This statement is incorrect, in that, as previously set forth above, our review of the survey records revealed that contamination levels on the 10-fcot Elevation were high enouoh to reouire respiratory protection, while elsewhere in the accessible areas of the Containment, the contamination levels were not high enough to require respirators. This is a significant difference and certainly of signicicant maonitude to be considered consequential. Routinely, when work is being performed in high contamination areas, e.g., on the 10-foot Elevation, it is our oractice to use step-off pads at the perimter of these areas and exchange shoecovers when traversina these areas to prevent the transfer of the contamination from these areas to areas of lower contamination levels.

During the process of preparing the Containment for return to normal operations, all extraneous materials are removed from the Containment and the number of individuals workino in the Containment at this time is minimized. Therefore, the steo-off pad usage und shoecover removal is perforred at the boundary of the Containment. Shoecovers being reworn and used in other areas of the Containment during this time is unlikely. It is emphasized that this practice is used only as described above and when Containment entries are made during normal power operations.

Contrary to the statement included in paraoraph 3 of the " DETAILS" section of subject report, i.e., "the licensee representatives refused entry to the lowest level", assistance was in fact offered to the Inspector to allow him to perform his inspection. Respirator man-fitting was made available to him in order to

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-3 oualify him as a respirator user, but the offer was declined prior to his first inspection entry into the Containnent, therefore, he was restricted from entering the 10-fcot Elevation by his cmn choice. Following successful completion of the respirator man-fitting evaluation, the Inspector was aranted free cess, with the use of a respirator, to the 10-foot Elevation. As previously described, posting was not required for Airborne Radioactivity Areas, nor was the use of stands, ropes, and/or barricades, and the maintenance of step-off pads in this area required or appropriate under the circunstances of preparation to return to normal operations and the provisions of access control by continuous coverage by Rad-Chem.

Based on our review of the circumstances surrounding this item of apoarent non-compliance it is our opinion that contrary to the statements made in your inspection report we were at all times in full como11ance with Technical Specification 6.11 in that procedures for personnel radiation protection have been prepared consistent with the requirements et 10 CFR 20, are approved, maintained, and adhered to for all operations involving personnel radiation exposures. Consecuently, it is requested that you reconsider this item in light of the above infonnation.

We believe after your review you will detennine that this is not an item of noncompliance.