ML20067A143
| ML20067A143 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/17/1991 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9101240269 | |
| Download: ML20067A143 (3) | |
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BALTIMORE -
OAS AND ELECTRIC 7 CHARLES CENTER
- P.O. BOX 1475
- BALTIMORE. ' MARYLAND 21203 1475-
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4 GEonot C. Cacco Vect Pas siotNT j
Nuc6t an Intnov ao.>o.a...ss-January 17,1991 '
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 NRC insnection Report Nos. 50-317/90-32 and 50 318/90 32 -
Gentlemen:
The subject inspection report contained a Notice of Vialation regarding three instances of plant personnel entering High Radiation Areas without dose rate meters.' Our response to the Notice of Violation is provided in Attachment (1).
Should you have any further questlo'ns regarding this matter, we-will be pleased to discuss them with you.
Mery trulyyoursf
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Attachment
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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 -
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1 ATTACHMENT m NRC INSPECTION REPORT NOS. 50 317/90 32 AND 50-318/90 31 DESCRIPTION AND CAUSE OF VIOLATION On January 17,1990, during a ror:!ne Radiation Safety Technician (RST) inspection, two contractor personnel were found inside a posted High Radiation Area (HRA) witbout a continuously-monitoring survey instrument (dose rate meter). The contractors had observed other contractors routinely going in and out of the posted HRA for several days and did not notice them carrying dose rate meters. The two contractors had not received any dose on previous entries into this particular HRA.
On February 6,1990, an RST found a plant operator exiting a posted HRA without a dose rate :
meter. The operator had entered and surveyed the same area 30 minutes earlier and determined it -
was not an HRA. The operator had his hands full on the second trip. He therefore decided to proceed into the area without the meter based on his survey from the previous entry.
On June 13,1990, an RST found two contractor personnel in a posted HRA without a dose rate meter. The contractors incorrectly assumed that their RST haJ logged them into the HRA with the Special Control Point Watch (SCPW) and had gone into the HRA ahead of them. They crossed the i
radiological HRA boundary assuming the RST had taken care of their radiological requirements before entering the HRA.
The causes of these events were inattention to detail, plus a lack of concern for work controls and radiological hazards associated with HRAs In the first event, the two contractors believed that dose i
rate meters were not required in an HRA based on their perceptions that other personnel were entering the area without dose rate meters. The operator in the second event entered an HRA' without a dose rate meter even though he had seen and understood the HRA posting requirements.
This individual made a conscious decision to enter the HRA based on the results of his radiation survey 30 minutes earlier. The contractors in the third event incorrectly assumed that they had been logged into the HRA and that the RST would ensure appropriate radiological controls were met for -
entering the HRA.
Two Human 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 occurred. These evaluations identified the human factor contributors to these violations of HRA controls and provided recommended corrective actions.
o CORRECTIVE ACTIONS T11ATIIAVE 11EEN TAKEN AND TIIE RESULTS ACIllEVED-l l
l The personnel involved were immediately removed from the HRA.
The training qualification records of the personnelinvolved were evaluated. It was verified that each individual had been previously trained concerning the plant specific requirements for entering HRAs.
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- Appropriate disciplinary action was administered in each case, l
Because of the tc) cat nature of these events and indications of lack of concern and inattention to detai regarding entering HRAs, 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 expectaticns regarding strictly following 1
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' A'ITACIIMENT (1)
NRC INSPECTION REPO11T N_O& 50 317/90 32 AND.40 318. 90 -Radiation Control procedures and policies. - This issue was also emphasized to all-plant personnel via a handout memoran&m distributeJ at the facility exits.
Plant Management has continued.to emphasize the importance of attention to detail and -
maintaining a questioning 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 HRA boundaries has been evaluated and improved.
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.The events have been incorporated into the " Industry Events" section of our -General q
Orientation Training (GOT) Initial and 1991 requalification training program for the next training cycle, GOT programs have been changed to include mockup training for all contractor workers.
Work practices and procedures for RSTs have been standardized to require cach worker in y
an HRA log himself into tne access log for that area. RSTs are no' longer allowed to log other personnelinto HRAs, A " Hands Free" portable survey instrument has been placed in service, This instrument will-be available for instances where an. individual entering an HRA has both hands full or occupied.
i CORRECI'IVE ACTIGNS TIIATWILL llE TAKEN TO AVOID FURTIIER VIOLATIONS 1
A training video tape is currently being created to visually demonstrate the requirements for entering
- HRAs, 1
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.
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J)W['E WIIEN FULL COMPLIANCE WAS ACIIIEVED Full compliance was achieved for each respective event when the personnel involved were immediately removed from the HRAs.'
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