ML20132E714
| ML20132E714 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/12/1985 |
| From: | Clemons P, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20132E707 | List: |
| References | |
| 50-317-85-17, 50-318-85-15, NUDOCS 8507180056 | |
| Download: ML20132E714 (6) | |
See also: IR 05000317/1985017
Text
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Region I
50-317/85-17
Report No.
50-318/85-15
50-317
Docket No. 50-318
D PR- 53
License No. O PR- 69
Priority
Category
C
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Licensee:
Baltimore Gas and Electric Company
P. O. Box 1475
Baltimore, Maryland 21203
Facility Name:
Calvert Cliffs Nuclear Power Plant
Inspection at:
King of Prussia, Pennsylvania
Inspection conducted: July 1-3,1985
Inspectors:
D.
Ibl4 F
.
P. Clemons, Radiation Specialg
dagsiQned
V
Approved by:
M k.
g4 ) y g cg pf
M. Shanbaky, Chief
M
0 dat( sighed
PWR Radiation Safety Section
Inspection Summary:
Inspection on July 1-3,1985 (Report Nos.' 50-317/85-17 and 50-318/85-15)
Areas Inspected:
A special, in-office radiological safety inspection of licensee and NRC
records and documents relevant to the allegations raised by a licensee employee on
September 19, 1984. The inspection involved 20 in-office hours by one region based
i ns pector.
Results: Two violations were identifled (licensee pennitted one employee to receive
more than 1,250 millirem a quarter during two separate quarters without completing the
applicable requirements of 20.101(b) and 20.102(b) & (c), paragraph 3; and the
licensee failed to report the over exposure as required by 10 CFR 20.405, paragraph 4).
This apparent overexposure, although in excess of certain federal limits, does not
constitute a significant safety issue, since the individual's exposure was controlled
less than 3,000 millirem per quarter, a limit that would have been authorized had
appropriate papomork been completed prior to the exposure.
g7180056850712
G
ADOCK 05000317
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DETAILS
1.
Individual Contacted
a.
Licensee Personnel
J. Tiernan, Manager, Nuclear Power Department
L. Russell, Plant Superintendent
N. Millis, General Supervisor, Radiation Safety
b.
NRC Personnel
T. Elsasser, Section Chief, DRP
J. Gutierrez, Region I Counsel
T. Foley, Senior Resident Inspector
2.
Purpose
The purpose of this inspection was to re-examine the relevant facts
surrounding several allegations raised by a radiological worker at
the Calvert Cliffs Nuclear Power Plant, as a result of additional
discussions with the worker and his attorney.
These allegations
had previously been reviewed by NRC Region I and the resulting
findings were documented in Combined NRC Inspection Report Nos.
50-317/84-25 and 50-318/84-25, which was transmitted to the li-
censee on December 10, 1984.
The worker was informed about the
status of the NRC followup on the allegations in a letter from NRC
Region I dated November 21, 1984.
During a recent discussion between the worker and the NRC Region I
staff on June 24, 1985, the worker maintained that the following
concerns were not fully addressed by the NRC or the licensee:
a.
The licensee changed his NRC Form 4 without his consent;
b.
The licensee did not determine his prior occupational exposure
before allowing his exposure to exceed 1250 millirem per
quarter;
c.
He received a potential exposure in excess of regulatory
limits;
d.
The licensee improperly placed a new address and date on a
previously signed release form, permitting the licensee to
obtain his exposure history; and,
e.
His name was improperly removed from the licensee's computer
list of individuals whose exposure should not exceed 1250
millirem per quarter.
During this inspection these concerns were re-examined by reviewing
the individual's exposure records.
Licensee's documented actions
were also reviewed by the inspector.
As a result of this
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re-evaluation, the allegations were substantiated, in part, as more
fully set forth below.
3.
Exposure Control
Certain aspects of the licensee's external exposure control program
were reviewed against the criteria contained in 10 CFR 20.101,
" Radiation dose standards for individuals in restricted areas".
The licensee's performance relative to these criteria was de-
termined by reviewing radiation exposure data, combined NRC Region
I
Inspection Report 50-317/84-25, and 50-318/84-25, and other
supporting documents.
Within the scope of this review, the following violation was
identified.
The inspector determined that an individual was hired at the
Calvert Cliffs site by a security firm during March 1982.
Docu-
ments reviewed indicated that the licensee made an attempt to
acquire the individual's occupational exposure history, but was not
successful in that needed exposure information was not received
from the U. S. Army. During the period of October - December 1983,
the licensee's radiation exposure records show that the individual
received a total dose of 1672 millirem.
In addition, during the
period of April 1 - June 30,1984, the same individual received a
whole body exposure of 1658 millf rem.
In each case, the licensee
had
not determined
the
individual's accumulated occupational
exposure prior to the exposure.
10 CFR 20.101(a), " Radiation dose standards for individuals in
restricted areas", states that except as provided in paragraph
20.101(b), a licensee may not cause any individual in a restricted
area to receive in any period of one calendar quarter a whole body
dose in excess of 1250 millirem.
10 CFR 20.101(b) states that a licensee may permit an individual in
a restricted area to receive a whole body dose in excess of 1,250
millirem provided:
The licensee has determined the individual's
accumulated occupational dose to the whole body on Form NRC-4, or
on a clear and legible record containing all the information
required in that form; and has otherwise complied with the require-
ments of 20.101(b) and 20.102.
Exposing an individual to a whole body dose in excess of 1,250
millirem in a calendar quarter prior to fulfilling all of the
requirements of 10 CFR 20.101(b) represents an apparent violation
of the regulations (317/85-17-01 and 318/85-15-01).
Although these exposures constitute an exposure in excess of
federal limits, they do not constitute a significant safety issue,
since the individual's exposure was being controlled to less than 3
Rems per quarter, a limit that would have been authorized had the
licensee appropriately completed the Form NRC-4 prior to these
exposures.
Nonetheless, it is of concern to the NRC that the
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licensee's dosimetry controls permitted the exposure limit of 1.25
Rems per quarter to be violated without completion of required
occupational radiation exposure records.
In Combined Inspection Report 50-317/84-25 and 50-318/84-25, it was
noted that the licensee had performed a calculation pursuant to 10 CFR 20.102, " Determination of prior dose", which allowed the
establishment of a 3 Rem per quarter 1imit.
The calculation,
although done properly, was performed by the licensee after the
licensee had identified the over-exposures and was involved in the
assessment of their significance.
As stated in 10 CFR 20.102 such
a calculation must be performed before permitting any individual to
receive an occupational exposure in excess of the limits specified
in 10 CFR 20.101(a).
10 CFR 2, Appendix C, instructs the NRC not to issue a notice of
violation under certain conditions, in an effort to " encourage and
support licensee initiative for self-identification and correction
of problems."
Previous correspondence on the concerns raised by
the allegations
in
Inspection
Report
Nos.
50-317/84-25
and
30-318/84-25 concluded that this criteria had been satisfied.
However, further evaluation has shown that the exposure was never
reported as required by 20.405(a) and (b) and therefore, we are
issuing the apparent violation at this time.
4.
Reports of Overexposures
10 CFR 20.405(a) requires each exposure of an individual to radia-
tion in excess of the limits specified in 10 CFR 20.101 be reported
in writing to the U.S.
Nuclear Regulatory Commission, Document
Control Desk, Washington, DC 20555, with a copy to the appropriate
NRC Regional Office, within 30 days of the occurrence.
Each such
report must describe the extent of exposure to individuals to
radiation including:
estimate of individual
exposure as
required by 10 CFR
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20.405(b)
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levels of radiation involved; and
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corrective steps taken or planned to prevent recurrence.
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The licensee determined that on two occasions (details, Paragraph 3
of this report) an individual was exposed to radiation in excess of
the limit specified in 10 CFR 20.101(a).
No written reports were submitted to the NRC in accordance with
these requirements.
Failure to report these overexposure consti-
tuted an apparent violation of 10 CFR 20.405 (317/85-17-02 and
318/85-15-02).
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5.
Allegation Concerns
Based on the information obtained as a result of this inspection,
each of the alleger's concerns as expressed in Section 2 can be
addressed as follows:
a.
Allegation - The licensee changed his NRC Form 4 without his
consent.
Finding -
The records indicate that the alleger's original
Form 4 may have been changed, apparently to
obtain a more complete exposure history on the
alleger.
During the June 24, 1985 meeting, the
alleger indicated this was done without his
consent.
The alleger, previously informed the
Senior Resident Inspector that the change had
been performed with his consent. Baltimore Gas
and Electric Company is requested to address this
concern in its response to the enclosed notice of
violations.
b.
Allegation - The licensee did not determine his prior
occupational exposure history before allowing his
exposure to exceed 1250 millirem per quarter.
Finding -
This allegation is substantiated and has resulted
in the issuing of the enclosed notice of
violation (50-317/85-17-01 and 50-318/85-15-01).
c.
Allegation - The licensee improperly placed a new address and
date on a previously signed release form
permitting the licensee to obtain his exposure
history.
Finding -
Our independent review of records indicate that
this allegation is substantiated.
The licensee's
actions apparently were an attempt to obtain as
complete an exposure history as possible on the
alleger. Baltimore Gas and Electric Company is
requested to address changing a release form in
its response to the enclosed notice of
violations,
d.
Allegation - His name was improperly removed from the
licensee's computer list of individuals whose
exposure snould not exceed 1250 millirem per
quarter.
Finding -
A review of your computer records indicates that
the alleger's name was improperly removed from
the list of individuals whose exposure should not
exceed 1250 millirem per calendar quarter. This
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resulted in the violation cited above in Section
3 (317/85-17-01 and 318-85-15-01). Baltimore Gas
and Electric is required to address this matter
in accordance with Appendix A to this Inspection
Report.
e.-
Allegation - He received a potential exposure in excess of
regulatory limits.
Finding -
This allegation is substantiated and has resulted
in the issuing of the enclosed notice of
violation (50-317-17-01and50-318/85-15-01).
6.
Exit Interview
Discussions were held with licensee representatives in a telephone
conference call on July 12, 1985.
The inspector summarized the
purpose and scope of the inspection, and the inspection findings.