ML20096H614

Responds to NRC Re Violations Noted in Insp Repts 50-317/92-13 & 50-318/92-13 on 920413-17.Corrective Actions: Sys Software Has Been Modified to Specifically Accommodate resin-sample Analysis & Procedure Was re-written

ML20096H614
Person / Time
Site:	Calvert Cliffs
Issue date:	05/21/1992
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9205270306
Download: ML20096H614 (3)

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GALTIMORE GAS AND ELECTRIC 1650 CALVERT CUFFS PARKWAY a LUSBY, MARYLAND 20057 4702 Gronot C Cntct ggg,

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gy WC4 tan thtmov (eiosreo-east U. S. Nuclear Regulatory Commission Washington, DC 20555 A'ITENTION

Document Control Desk SUI 33ECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & $0 318 NRC Region 1 Inspection Report Nos. 50 317N213 and 50-318N2-13 i Antil 13 17.1992)

REr'ERENCE:

(a) 1xtter from hir. J.11. Joiner (NRC) to hir. G. C. Creel IllO&E),

NRC Region i Inspection Report Nos. 50-317N213 and 50-318N213

( April 13 17, lW2), dated April 21, lW2 Gentlemen:

Reference (a) forwarded a Notice of Violation [ Appendix A to Reference (a)) regarding inconect resin-waste shipment manifests. Attachment (1) provides our response to this Notice of Violation as requested.

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

Very truly yours,

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GCC/REF/ref/bjd Attachment ce:

D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. hicDonald, Jr., N RC

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P. R. Wilson, NRC t

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R.1. hiclean, DNR J.11. Walter, PSC f

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i 9205270306 920521 QCR ADocK osooo337 PDR

s 6l TAC ll$1ENTIO REPIN TO A M)TICE OF VIO!ATION INSPECI'lON REPORT NOS. 50 317/9213 ANI) 50 3tR/9213 VIOld110N NO, i 1.

DESCRIPTLON ANI) CAUSE Ol'_YlOIATION Appendix A of Refetence (a) Notice of Violation, cites five shipments e radioactive spent resin to a waste. management facility. These were shipped and buried with incorrect manifests which over.

reported their radionuclide contents hy about 20 percent. Although these shipment manifests were overly conservative, they were not in strict compliance with 10 CFR Parts 71.5 and 20.311.

11altimore Gas and Electric Company self identitled these violations as a result of programmatic improvement and scif assessment efforts. We promptly reported them to both our denior Resident inspector and a Region i Senior Radiation licaith Specialist.

The shipments occurred between htarch IW1 and h1 arch IW2. De event root cause is linked to the acquisition of new chemistry lab equipment iust prior to this time. The equipment, a compr' rited gamma. scanning system, was to be set up tot analyzing a variety of samples. The programmatic controls established by Chemistry management did not adequately ensure that all of htaterials Pmeessing's sample requirements were met.

Chemistry did not identify resin. waste analysis as a system requirement. They did not specifically set up the system to accommodate resin samples. The reasor,s this occurred include: the resin waste analysis is infrequent making it difficult to t igle out Chemistry thought of this type of equipment as their own and did not recognize others as end. users; and the analysis procedure was general and did t

not specifically address resin, in adcA., the software intensive nature of the analysis contributed to Chemistry's failure to detect the errors.

llecause no software function for resin analysis existed, the software validation and verification process did not detect the quality problem. llad the resin waste analysis requirement been identified and accommodated, the analysis process could hase been checked. The Notice of Violation incorrectly described the software as having been set up with the wrong parameters.

When performing an analysis, technicians select a resin sample geometry from the system menu.

Current practice was to select an ec uivaler.t sample geometry. This geometry was intended for volumetric samples (i.e., samples una yzed by volume (cc)). Resin is weighed out and analyzed in grams. This geometry produced correct concentrations for pCilgm. but reported activity units as pCi!ce.

Chemistry reported these results in pCi/cc and hinterials Processing used this information in developing the shipping manifests.11ecause resin is less dense than 1 gm/cc, the use of pCi/cc instead of pCi/gm resulted m shipment activity over reporting.

On one early occasion, techniciar.s annotated correct units onto the analysis report. We believe an acute attention to detail allowed them to do this. They correctly believed they were providing good

. analysis to hiaterials Pmcessing. They did not, however, fully understand how the analysis was used and didn't realize they had found an interdepartm:.ntal problem. Chemistry's lack of knowledge on how the data was used contributed to inadequate data review.-

Folkiwing an earlier procederni compliance issue hiaterials Processing personnel received training emphasizing the need for a questioning attitude. This training led hiatenals Pmeessing personnel to question a subsequent analysis, resulting in discovery of the problem.

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ATIATSMENT (1)

REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-317/9213 AND 50-318/9213 VIOLATION NO. I II.

CORRECflVE STEPS TAKEN AND itESULTS ACillEVED The following corrective actions have been taken;

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the system software bas been m dified to specifically acecmmodate resin-sampie

analysis,

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a procedure addressing resin-sample analysis has been written that requires an analysis supenisory resiew,

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Materials Processing Unit correcte1 the manifests and informed the waste-management facility of the correcFons.

These corrective actions fixed the analytical problems and allow us to ship resin wastes today.

111.

CORRECTIVE ACTIONS WillCil Wil:L llE TAKEN TO AVOID FURTilER VIOLATIONS To avoid future siolations, Chemistry will take the following actions;

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develop a program.o ensure analysis end-ucts are more directly considered in future

projects,

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casure appropriate procedures are written for o:Ser tasks identified as infrequently performed,

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continue to emphasize management expectations with regards to maintaining a questioning attitude.

IV.

DATE WilEN FULL COMI'LIANCE WILL llE ACillEVED Full compliance was achieved on March 19, 1992 when resin waste shipment 92-014 was seat correctly to the waste-management facility.

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