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Forwards Insp Repts 50-317/97-02 & 50-318/97-02 on 970302-0412 & Nov.Several Apparent Violations That Are Being Considered for Escalated Enforcement Action IAW General Statement of Policy & Procedure, Were Identified
	ML20140B224
Person / Time
Site:	Calvert Cliffs
Issue date:	05/29/1997
From:	Hehl C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cruse C; BALTIMORE GAS & ELECTRIC CO.
Shared Package
ML20140B228	List: ML20140B224; ML20140B235;
References
	50-317-97-02, 50-317-97-2, 50-318-97-02, 50-318-97-2, EA-97-192, NUDOCS 9706060109
	Download: ML20140B224 (4)
	v • d • e

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May 29, 1997

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EA No.97-192

Mr. Charles H. Cruse

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Vice President - Nuclear Energy

Baltimore Gas and Electric Company (BGE)

Calvert Cliffs Nuclear Power Plant

1650 Calvert Cliffs Parkway

Lusby, MD 20657 -4702

SUBJECT: NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-02 :

AND 50-318/97-02 AND NOTICE OF VIOLATION

Dear Mr. Cruse:

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This refers to the inspection conducted at the Calvert Cliffs Nuclear Power Plant from

j March 2,1997 to April 12,1997 and on April 24,1997. The enclosed report presents the

results of the inspection. At the conclusion of the inspection, these findings were -

discussed with Mr. Katz and others of your staff.

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Based on the results of this inspection, the NRC has determined that a violation of NRC

requirements occurred. This violation is cited in the enclosed Notice of Violation (Notice)

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and the circumstances surrounding the issue are described in detail in Section E1.4 of the

enclosed inspection report. The violation concerns inadequate corrective actions following

identification of degraded conditions for one of the Unit 1 power operated relief valve block

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valves.

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You are required to respond to the enclosed Notice and should follow the instructions

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specified in the Notice when preparing your response. in your response, you should

q document the specific actions taken and include any additional actions you plan to prevent

recurrence. Your response may reference or include previous docketed correspondence, if

the correspondence adequately addresses the required response. After reviewing your

response to the Notice, including your proposed corrective actions and the results of future

g inspections, the NRC will determine whether further NRC enforcement action is necessary

Ya, to ensure compliance with NRC regulatory requirements.

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in addition, several apparent violations were identified that are being considered for

So escalated enforcement action in accordance with the " General Statement of Policy and

Y Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. As

described below, the apparent violations involve the series of problems identified during

'84 fuel handling operations, and control of high radiation area access including the failure to I

jg effectively control diving activities in the Unit 2 spent fuel storage pool.

The fuel handling problems included the poor material condition of the fuel handling

equipment, operation of the refueling equipment contrary to the Technical Specification

060003

h !,hh lh 0FFICIAl. RECORD COPY IE:01

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j Charles H. Cruse 2

requirements, failure to use engineering drawings during troubleshooting, and the failure to

follow fuel handling procedures.

On April 3,1997, your staff failed to effectively control diving activities in the Unit 2 spent

fuel storage pool and as a result, a diver moved from a comprehensively surveyed area at

the south end of the pool to unsurveyed areas at the north end of the pool. The diver

sustained an unplanned exposure. Although no exposure in excess of regulatory limits is

believed to have occurred, we are concerned that sufficient measures were not employed

to provide positive contrnt of this activity which involved very high levels of radiation.

Specifically, due to insufficient controls, including inadequate pre-job planning and

communication, and lack of positive surveillance, the individual inadvertently came in close

proximity to radiation fields in excess of 500 rads per hour.

During the inspection period, we also noted a failure to control access to the Unit 2

containment, a high radiation area, via the emergency airlock, and a failure to properly

document the problem in the corrective action system. Additionally, on May 1,1997, a

worker performed maintenance for over one hour in a locked high radiation area inside the

Unit 2 containment without any dosimetry. Subsequently, on May 4, two workers

inadvertently gained access to a high radiation area during the construction of scaffolding

in the Unit 2 auxilian :uilding. Although the last two problems occurred outside the

inspection period, those issues, in conjunction with the loss of control of the diver, were

considered to reflect an apparent breakdown in the applied radiation protection program,

specifically the control of high radiation area access at Calvert Cliffs.

Accordingly, no Notice of Violation is presently being issued for these inspection findings.

In addition, please be advised that the number and characterization of apparent violations

described in the enclosed inspection report may change as a result of further NRC review.

A predecisional enforcement conference to discuss these apparent violations has been

scheduled for June 12,1997 at 10:00 a.m. The decision to hold a predecisional

enforcement conference does not mean that the NRC has determined that a violation has

occurred or that enforcement action will be taken. This conference is being held to obtain

information to enable the NRC to make an enforcement decision, such as a common

understanding of the facts, root causes, missed opportunities to identify the apparent

violation sooner, corrective actions, significance of the issues and the need for lasting and

effective corrective action. In particular, we expect you to address the apparent lack of

effective management oversight in both fuel handling and high radiation area access

control, including the May 1 and May 4 high radiation area access problems, as well as the

effectiveness of your corrective action processes in identifying and correcting problems in

these areas, in addition, the conference is an opportunity for you to point out any errors in

our inspection report and for you to provide any information concerning your perspectives

on 1) the severity of the violations, 2) the application of the factors that the NRC considers

when it determines the amount of a civil penalty that may be assessed in accordance with

Section VI.B.2 of the Enforcement Policy, and 3) any other application of the Enforcement

Policy to this case, including the exercise of discretion in accordance with Section Vll.

You will be advised by separate correspondence of the results of our deliberations on these

matters. No response regarding these apparent violations is required at this time.

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I Charles H. Cruse 3 1

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,

its en::losures, and your response will be placed in the NRC Public Document Room (PDR).

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Sincerely, fs

Original Signed by:

Larry Nicholson for ,

Charles W. Hehl, Director

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Division of Reactor Projects

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Docket / License Nos: 50-317/DPR-53 )

[ 50-318/DPR-69 '

Enclosures:

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1. Notice of Violation '

2. NRC Region I integrated Inspection Report Nos. 50-317/97-02

and 50-318/97-02

cc w/encls:

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T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)

! R. McLean, Administrator, Nuclear Evaluations

l- J. Walter, Engineering Division, Public Service Commission of Maryland

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K. Burger, Esquire, Maryland People's Counsel

R. Ochs, Maryland Safe Energy Coalition

State of Maryland (2)

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Charles H. Cruse 4

Distribution w/encis:

W. Axelson, DRA J

D. Screnci, PAO l

R. Zimmerman, ADPR, NRR l

J. Goldberg, OGC l

J. Lieberman, OE (OEMAIL) l

D. Holody, EO, RI l

Nuclear Safety Information Center (NSIC) !

PUBLIC l

NRC Resident inspector

Region i Docket Room (with concurrences)

R. Correia, NRR

F. Talbot, NRR

L. Cunningham, NRR

D. Barss, NRR

L. Doerflein, DRP i

J. White, DRS

T. Moslak, DRP'

R. Junod, DRP

Distribution w/ encl: (VIA E-MAIL) !

W. Dean, OEDO (WMD)

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S. Stewart - Calvert Cliffs j

S. Bajwa, NRR ,

A. Dromerick, NRR

G. Vissing, NRR

M. Campion, RI

Inspection Program Branch, NRR (IPAS)

DOCDESK

DOCUMENT NAME: G:\ BRANCH 1\CC9702.lR

To r: ceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment / enclosure "N" = No copy

OFFICE Rl/DRP n, FK/QRS , Rl/DRP l, Rl/DRP/ h '

. NAME SStewart ,y$ b j$its LDoerflein blT4/ CHehlg "

DATE 05/27/97 ll #' 05/ /97 05/21/97 05 0 /97

l OFFICIAL RECORD COPY

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ML20140B224

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