ML20035D484
| ML20035D484 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/01/1993 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9304130256 | |
| Download: ML20035D484 (3) | |
See also: IR 05000317/1992025
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APR 011993
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Docket Nos. 50-317
50-318
Mr. Robert E. Denton
Vice President - Nuclear Energy
Baltimore Gas and Electric Company
Calvert Cliffs Nuclear Power Plant
1650 Calvert Cliffs Parkway
Lusby, Maryland 20657 - 4702
Dear Mr. Denton:
Subject:
NRC Combined Inspection Report Nos. 50-317/92-25 and 50-318/92-25
This letter refers to your February 25,1993 correspondence, in response to our
January 21,1993 letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. The resident staff will examine these actions during their current inspection report
period.
Your cooperation with us is appreciated.
Sincerely,
Curtis J. Cowgill, Chief
Projects Branch No.1
Division of Reactor Projects
OFFICIAL RECORD COPY
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Mr. Robert E. Denton
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cc w/ encl:
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G. Dette, virector, Nuclear Regulatory Matters (CCNPP)
R. McLean, Administrator, Nuclear Evaluations
J. Walter, Engineering Division, Public Service Commission of Maryland
K. Burger, Esquire, Maryland People's Counsel
R. Ochs, Maryland Safe Energy Coalition
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K. Abraham, PAO (23) SALP Reports and (2) All Inspection Reports
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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OFFICIAL RECORD COPY
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Mr. Robert E. Denton
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Region I Docket Room (with concurrences)
C. Cowgill, DRP
J. Yerokun, DRP
L. Nicholson, DRP
S. Greenlee, DRP
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P. Wilson, SRI - Calvert Cliffs
V. McCree, OEDO
R. Capra, NRR
D. Mcdonald, NRR
DRS/EB SALP Coordinator
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BALTIMORE '
GAS AND
ELECTRIC
1650 CALVERT CLIFFS PARKWAY . LUSBY, MARYLAND 20657-4702
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Rose AT E. DENTON
vice eacsecur
February 25,1993
NUCLcAR ENERGY
(dio) 260-4455
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 & 50-318
Reniv to Notice of Violation. Inspection Report No. 92 25
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REFERENCE:
(a)
Letter from Mr. T. T. Martin (NRC) to Mr. R. E. Denton (BG&E),
dated January 21, 1993, Inspection at Calvert Cliffs Units 1 and 2,
NRC Combined Inspection Report Nos. 50-317/92 25 and
50-318/92 25
Gentlemen:
Attachment (1) is provided as our response to Reference (a).
Should you have any further questions regarding this matter, we will be pleased to discuss them with
you.
--- Yr.v truly yours,
r
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RED /JV bjd
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Attachment
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cc:
D. A. Brune, Esquire
J. E. Silberg, Esquire
R. A. Capra, NRC
D. G. Mcdonald, Jr., NRC
T. T. Martin, NRC
P. R. Wilson, NRC
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R. L McLean, DNR
J. H. Walter, PSC
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NITACHMENT m
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REPLY TO NOTICE OF VIOIATION
INSPECTION REPORT NO. 02-25
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Notice of Violation 50-317/92-25 and 50-318/92-25 identifies two instances where personnel entered
High Radiation Areas (HRA) without a radiation monitoring device which continuously indicates the
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radiation dose rate in the area (dose rate meter), contrary to Technical Specification 6.12.1. On
August 13,1992, a contractor Containment Coordinator and three other individuals entered a posted
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HRA (Event A), and on September 17,1992, a Senior Reactor Operator (SRO) entered a locked
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HRA (Event B) without a dose rate meter.
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DESCRIPTION AND CAUSE OF EVENT.
A.
On August 13,1992, a contractor Containment Coordinator and another contractor
had the task of a containment walkdown prior to containment closure. Two
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contractor Decontamination Technicians (Decon Techs) were to assist the
Containment Coordinator by picking up and disposing of any trash during the
walkdown. The two Decon Techs signed into the Containment under Special Work
Permit (SWP) 92-1002A, " routine decontamination, waste and laundry collection in
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controlled areas." The other two contractors signed in under SWP 92-1017A,
" mechanical minor maintenance in general areas of containment as approved by the
Radiological Control Shift Supervisor " Both SWPs were for performing work in the
Containment. The primary difference between the two SWPs was the allowable dose
rate limit. SWP 92-1002A had an area dose rate limit of 300 mr/hr and allowed work
in HRAs with an RST escort and a dose rate meter. SWP 92-1017A had a limit of
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100 mr/hr and did not allow entry into HRAs.
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Prior to entering containment, the Containment Coordinator talked to the SWP
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Coordinator (SWPC). The SWPC advised the Containment Coordinator that there
were no Radiation Safety Technicians (RST) available to support him. For entry by
mher than certain operators iG a HRA, an RST was required by procedure to
accompa:peleers and cny a dose rate meter. The SWPC gave the Containment
Coordinator general access to the containment, without permission to enter HRAs,
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for his walkdown.
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At the containment access hatch, the Containment Coordinator met a RST who
advised the Containment Coordinator that there was no RST in the containment.
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The Containment Coordinator acknowledged the RST and went into the
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containment with the other contractor and the Decon Techs. After walking down the
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69 foot level of the containment, the Containment Coordinator and one of the
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Decon Techs went to the ladder leading down to the 12 Reactor Coolant Pump
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(RCP) bay. A posting at the top of the ladder designated the area starting at the top
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of the ladder a HRA. The Containment Coordinator began descending down the
ladder when the Decon Tech questioned him about the HRA posting. The
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Containment Coordinator advised the Decon Tech that he had talked to Radiation
Control and it was okay to enter the HRA. Both men descended the ladder, followed
by the other Decon Tech and the other contractor. After the walkdown, all four
exited the HRA and the containment.
When at the SWPC desk, the Containment Coordinator advised the SWPC that
there was still some scaffolding in the 12 RCP bay. The SWPC concluded that the
only way the Containtnent Coordinator could have seen the scaffolding was if he had
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been in 12 RCP bay. He asked the Containment Coordinator if he had been in the
12 RCP bay. The Containment Coordinator said he had. It was then determined that
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NITACIIMENT m
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REPLY TO NOTICE OF VIOIATION
INSPECTION REPORT NO. 92-25
the Containment Coordinator and the three other people enterec' the HRA without
an RST or a dose rate meter.
The cause of this event is that the Containment Coordinator apparently consciously
decided not to heed the verbal, written and posted instructions and requirements
regarding entry into HRAs. He apparently felt he had adequate knowledge of the
area and the radiological consequences were perceived as being small.
B.
On September 17, 1992, a Senior Reactor Operator (SRO) acting as the Shift
Supervisor Assistant (SSA) went to verify Unit 1 valve 1-CVC-254 was locked shut.
At first he mistakenly went to Unit 2 valve 2-CVC-254, which is in a passageway in
the Auxiliary Building and not in a HRA. After checking the valve label and realizing
his mistake, he proceeded to the Unit i valve.
The Unit 1 valve is about 25 feet away from the Unit 2 valve. The Unit 1 valve is
located inside the Volume Control f ank (VCT) room. which is a posted locked
HRA. Locked HRAs contain areas where radiation dose rates are 1000 mr/hr or
more. The SSA found the door locked, as required, and unlocked it with the locked
HRA key he had. Certain Operations personnel, such as the SSA, routinely carried
such a key and were qualified to enter HRAs, including locked HRAs, without an
RST as long as they had a dose rate meter. He entered the room to verify
1-CVC-254 was locked shut. After going about 20 feet, he realized the flashing
strobe light he had passed indicated that he was in a HRA. Realizing he had entered
the HRA without a dose rate meter, he immediately left the room without having
verified 1-CVC-254 locked shut. Upon miting the VCT room, the SSA met a RST
who asked him if he had a dose rate meter. The SSA replied he did not. The RST
and SSA went to the Radiation Control- Operations Supervisor's office and reported
the event.
The cause of the event was a lapse in concentration on the part of the SSA.
II.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED.
A.
The path in the HRA along which the personnel travelled was surveyed. The
personnel were not in any areas where the radiation was greater than 30 mr/hr.
Controlled area access was removed for the Containment Coordinator and the two
Decon Techs. The other contractor left the site before action could be taken, but his
employer was notified of the event. Key site personnel and the NRC were notified of
the event.
Calvert Cliffs conducted an investigation into the event.
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Containment Coordinator was counseled before leaving at the end of his contract,
and his radiologically controlled area access was permanently removed after he had
left the site. The Decon Techs received disciplinary action. The event was discussed
with site personnel at a safety break.
B.
The VCT room was surveyed after the event. The SSA was not in any areas where
the radiation was greater than 10 mr/hr. Key site personnel and the NRC were
notified of the event. Calvert Cliffs conducted an investigation. The SSA received
disciplinary action. The General Supervisor - Nuclear Plant Operations discussed
radiological safety philosophy with each Operations crew. The SWP and radiological
control briefings were improved to ensure operators were adequately briefed on
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A1TACIIMENT (1)
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REPLY TO NOTICE OF VIOLATION
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INSPECTION REPORT NO. 925
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radiation areas during their shift. Control of all the keys for locked HRAs was given
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to Radiation Safety in order to enhance operator knowledge of radiation areas by
conducting briefings during issuance of the keys. The training program has been
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upgraded to provide more radiation worker training to Operators. A Plant General
Manager memo was sent to all site supervisors and a site wide safety break was held
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to alert personnel about the two incidents. Another Plant General Manager memo
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was sent to all site supervisors Mdressing the need to comply with requirements, the
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potential for changing radiation levels in HRAs, and the potential personal health
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hazards and disciplinary actions for not complying with HRA requirements. This
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memo was discussed at site-wide tailgate meetings.
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CORPECTWE STEPS WIIICII WILL llE TAKEN TO AVOID FURTIIER VIOLATIONS.
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Management will re-emphasize the importance of radiation safety, including providing plant
personnel with descriptions of disciplinary actions taken in selected events wherc
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expectations are not met. Additional emphasis will be placed on the potential personal
health hazard, the potential for changing radiation levels in HRAs and the potential for
disciplinary action.
IV.
DATE WHEN FULL COMPLIANCE WILL BE ACIIIEVED.
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Full compliance was achieved August 13,1992 for Event A and September 17,1992 for
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Event B, when the personnel involved in the respective events left the HRAs and action was
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taken to verify they had not exceeded any radiation dose limits.
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