ML20151K181
| ML20151K181 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/31/1997 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-317-97-03, 50-317-97-3, 50-318-97-03, 50-318-97-3, NUDOCS 9708050362 | |
| Download: ML20151K181 (3) | |
Text
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I chant.Es II. CRUSE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 July 31,1997 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 Realv to a Notice of Violation -- Insoection Reoort Nos. 50-317(318V97-03
REFERENCE:
(a)
Letter from Mr. L. T. Doerflein (NRC) to Mr. C. H. Cruse (BGE), dated July 1,
1997, NRC Region I Integrated Inspection Report Nos. 50-317/97-03 and 50-318/97-03 and Notice of Violation in response to Reference (a), Attachment (1) details our response to the cited violation concerning documentation ofproblems and corrective actions in our corrective actions process.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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CHC/DWM/bjd Attachment
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cc:
R. S. Fleishman, Esquire Resident Inspector, NRC J. E. Silberg, Esquire R.1. McLean, DNR A. W. Dromerick, NRC J. H. Walter, PSC Director, Project Directorate I-1, NRC L. T. Doerflein, NRC H. J. Miller, NRC 9708050362 970731[
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ATTACIIMENT (1)
NOTICE OF VIOLATION 50-317(318)/97-03-01 MULTIPLE EXAMPLES OF FAILURE TO DOCUMENT AND REPORT T
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MANAGEMENT SIGNIFICANT CONDITIONS ADVERSE TO QUALITY Notice of Violation 50-317197-03-01 and 50-318/97-03-01 describes a non-conformance concerning failures to document problems and corrective actions in our corrective actions process Violation states, in part, that:
As ofMay 20,1997, issue reports were not initiated. the cause of the condition and the corrective following sigmficant conditions adverse to quality: action taken had n 1.
On Ma-ch 15, technicians responded to apersonnelcontamination. The decontaminat efort was not done in accordance with radiation safetyprocedure RSP-1 107.
2.
On April 13, three Cobalt-60 sources were returned to Calvert Chfs by a vendor as a limitedquantity shipnent. The receipt sw vey showed up to 1 milliremper hour on cont which is greater Ihan limited quantity.
3.
On April 8, BGE identified that personnel were changing alarming dosimeter calibration setpoints in thefield One reason was that the radiation safetyproceslure RSP-1-129 was not beingfollowed.
1.
REASON FOR TIIE VIOLATION be generated for conditions adverse to quality identified by Gold Card System as "a process used... to identify and track the proper use, or misuse management tools which contribute to event free operation at Calvert Cliffs." This Notice of Violati Section personnel to document conditions adverse to qua documentation and verification of the corrective actions for these issu The Gold Card process was initiated in Operations in 1994 as a tool for identifying l to event-free operation. Plant Management has found the Gold Card process a useful self as tool and the use of this process was extended to Radiation Safety in late 1995 At the time th was identified, Gold Cards had been in use in Radiation Safety for approximately a year an o a on There was some misunderstanding concerning their use and the relationship between th Issue Report systems.
supervision that Gold Cards were an adequate means for identifying issu Since Gold Cards are reviewed by supervisors, it was believed that they would be elevated to Issue Repo by the supervisor during his review. In the cases discussed in this Violation, the w the issues believed that Gold Cards were an appropriate means of documenting the issues reviewing supervisors failed to recognize that Issue Reports were required. and the The cause of this event was less than adequate training of Radiation Safety personnel a the distinction between Gold Cards and Issue Reports combined with less than adequate ove Gold Ca,d Program by Radiation Safety management.
g of the Introductory training was provided in
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ATTACHMENT (1)
NOTICE OF VIOLATION 50-317(318)/97-03-01 MULTIPLE EXAMPLES OF FAILURE TO DOCUMENT AND REPORT TO 3
MANAGEMENT SIGNIFICANT CONDITIONS ADVERSE TO QUALITY November 1995 when the Gold Card Program was initiated in Radiation Safety. It did not discuss the relationship between the Gold Card and Issue Report systems. Contractor training in preparation for the 1997 Unit 2 Refueling Outage dwelled on Gold Card usage and did not place as much emphasis on the need for Issue Reports to document conditions adverse to quality. This contributed to the impression among Contractor Radiation Safety Section workers that Gold Cards were the means for identifying conditions adverse to quality.
H.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Radiation Safety Section personnel reviewed all Gold Cards issued since the beginning of the 1997 Unit 2 Refueling Outage. Three additional Issue Reports were generated as a result of this review.
All Radiation Safety Section persom-1 have been provided awareness training on this issue and on management's expectations conctrning le documentation of deficiencies and non-conformances via Issue Reports vice Gold Cards. Tin, dis 6nction between the two has been re-emphasized. All newly issued Gold Cards are being reviewed at Radiation Safety Section staff meetings to ensure that Issue Reposts are generated, if warranted. This practice will continue untii such time that the General Supervisor-Radiation Safe'y is satisfied that the Issue Report threshold is adequately understood by Radiation Safety supervision and personnel or Gold Card Program changes are implemented.
IIL CORRECTIVE STEPS WHICH WHL BE TAKEN TO AVOID FURTHFR VIOLATIONS An effort is currently underway to review Gold Card use on site and ensure that conditions adverse to quality noted via Gold Card are entered into the corrective action process.
IV.
DATE WHEN FULL COMPLIANCE WIII BE ACHIEVED Full compliance was achieved on July 18,1997, when all issues identified in this Notice of Violation and the subsequent review were correctly documented on Issue Reports.
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