ML20203F405
| ML20203F405 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/05/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203F390 | List: |
| References | |
| 50-317-97-06, 50-317-97-6, 50-318-97-06, 50-318-97-6, NUDOCS 9712170373 | |
| Download: ML20203F405 (3) | |
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ENCLOSURE 1
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' Baltimore Gas and Electric Company -
Docket / License Nos. 50 317; DPR 53 Calvert Cliffs Nuclear Power Plant 50 318; DPR-69
- During an NRC inspection conducted from September 14,1997 to November 1,1997, six
~ iolations of NRC requirements were identified.. In accordance with the " General v
Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the -
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violations are listed below:
. A. _
10 CFR 50.59 allows the holder of a license to make changes to the facility as.
- described in the safety analysis report, without prior commission approval, unless-
- the proposed change involves an unreviewed safety question.10CFR 50.59(b)(1) i requires that the licensee maintain records of changes and that these records L
include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question. - 10 CFR 50.71(e) requires that licensees periodically update the final safety analysis report to assure
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that the report contains the latest material developed.
. Contrary to the above, as of October 15,1997, the screening for the Installation of i
a 5600 gallon ammonium hydroxide storage tank, installed in 1986 and reviewed by l BGE in 1996, failed to include a written safety evaluation which provided the determination that the change did not involve an unreviewed safety question. The hazardous material consequence of a spill of ammonia as described in the December 30,1980, BGE letter to the NRC, referenced in the Updated Final Safety Analysis Report Section 1.8, Subsection Ill.D.3.4,-and UFSAR Figure 1-2 were revised by the -
-installation of the tank. As a result of not completing a safety evaluation, BGE also
- failed to update the final safety analysis report.
'.This is a Severity Level IV violation. -(Supplement 1) c B.
Calvert Cliffs Technical Specification 6.4.1 states that written procedures be established and implemented, covering the activities referenced in Appendix A of
- NRC Regulatory Guide 1.33, Revision 2, dated February 1978. The regulatory guide c includes in Section 6 (r), " Procedures for Combating Emergencies and Other-Significant Events, including, Other Expected Transients that may be Applicable."
Contrary _to the above, as of October 15/1997, BGE had neither established nor implemented a procedure for combating a spill from an ammonia storage tank
-located within the protected area boundary. Specifically, following a postulated
- ammonia spill, actions for combating the spill including alignment of control' room -
---ventilationi personnel response, and the need for self-contained breathing apparatus,- had not been established into written procedures.
LThis is a Severity Level IV violation. (Supplement 1)
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C.
Calvert Cliffs Technical Specification 6.4.1 states that written procedures shall be
established and implemented covering the activities recommended in Appendix A of NRC Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Section 7,(e)(4) provides for radiation protection procedures for contamination control.
Contrary to the above, as of November 1,1997, BGE had neither established nor implemented a procedure that provided contamination control from laundered and re-used Anti contamination clothing.
This is a Severity Level IV violation (Supplement IV).
D.
10 CFR 20.1501 states that each licensee shall make or cause to be made, surveys that may be necessuy to comply with the regulations in this part, and are reasonable to evaluate the potential radiological hazard that may be present.
10 CFR 20.1204 states that for the purpose of assessing dose, licensees shall take suitable measurements of concentrations of radioactive materials in air in work areas.
Contrary to the above, on September 16,1997, during seal replacement of the 11B reactor coolant pump (RCP), the air samples were not collected in a suitable location that would be representative of the airborne radioactivity to which affected workers were exposed as necessary to comply with 10 CFR 20.1204 This is a Severity Level IV violation (Supplement IV).
E.
Technical Specification 6.4.1 states that written procedures shall be established and implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Appendix A of Regulatory Guide 1.33, Revision 2, Section 7 e.(1) lists access control to radiation areas including a radiation work permit system. The Calvert Cliffs Radiation Safety Manual, Revision 1, Sections 1
6.2.l.3.e and 6.2.1.2.6 squire that each person working under a specific special (radiation) work permit (SWP) comply with the specific special work permit in all respects.
SWP No. 802, task C (remove /replaco 11B RCP seal) specified full protective i
clothing dress plus water resistant outer clothing, face shield, kneepads, and extra boots and gloves.
SWP No.11, task C (Inspections and minor maintenance in all areas following a reactor trip) specified that in the absence of respiratory protection or facial Anti-Cs, the thermoluninescent detector (TLD) be worn on the outside of the Anti-Cs, with l
the beta window not covered.
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Contrary to the above, on September 16,1997 during seal replacement of the 11B ieactor coolant pump, a worker actively performing radiological work as authorized by SWP 802, task C, was not wearing the protective clothing as specified by the SWP, in that the individual did not wear a face shield or water resistant outer clothing though engaged in handling the RCP eeal container, and spraying the seal with water to minimize airborne radioact;vity.
2.
Contrary to the above, on October 24,1997 during an initial containment entry following a reactor trip, two radiation safety technicians performing radiological work authorized by SWP 11, task C, were not wearing either respiratory protection or their TLDs on the outside of the Anti-C clothing, with the beta window not covered.
These are each a Severity Level IV violation (Supplement IV).
Pursuant to the provisions of 10 CFR 2.201, Baltimore Gas & Electric Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at the f acility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.
Dated at King of Prussia, Pennsylvania this 5th day of December 1997.
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