ML20217C109
| ML20217C109 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/20/1998 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| Shared Package | |
| ML20217C114 | List: |
| References | |
| 50-317-98-03, 50-317-98-3, 50-318-98-03, 50-318-98-3, EA-98-106, NUDOCS 9803260310 | |
| Download: ML20217C109 (5) | |
See also: IR 05000317/1998003
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March 20,1998 :
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EA 98-106 -
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Mr. Charles H. Cruse
Vice President - Nuclear Energy-
<
' Baltimore Gas and Electric Company
.Calvert Cliffs Nuclear Power P! ant
'1650 Calvert Cliffs Parkway
Lusby, MD' 20657-4702
fSUBJECT:
NRC INSPECTION REPORT NOS. 50-317/98-03 and 50-318/98-03 AND -
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Dear Mr. Cruse:
This refers to the inspection conducted on January 19-22 and 26-27, onsite, at the Calvert
Cliffs Nuclear Power Station, and continuing through February 17,1998,in the Region I
office to review information and documentation provided by your staff subsequent to the
onsite inspection. Ti,e findings of the onsite inspection effort were discussed with your
- staff on January 27,1998, by Mr. Ronald Nimitz of this office. Mr. John R. White of my
staff discussed the findings of the in-office review of radiological control performance,
during the May 1997, Unit 2 outage, with Mr. Peter Katz, Plant General Manager, on
February 20,1998.
The principal focus of the inspection was the follow-up and verification of corrective
actions, documented in your letter dated September 11, .1907, taken in response to
violations identified in our letter and Notice of Violation and Proposed imposition of Civil
Penalties, dated August 11,'1997, relative to the Unit 2 spent fuel pool diving event on
April 3,' 1997.~ During the January 1998 inspection, the inspector reviewed planning and
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. preparation for resumption of diving operations, and observed a diving evolution on
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January 19,-1998. The inspector also reviewed previous Unit 2 refueling outage
Lperformance in May 1997, planning for the April 1998 Unit 1 outage, and performance
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' relative to improvement of the radiation protection program.
- Our review 16dicated that your organization is actively continuing efforts to establish and
irhplement aorrective actions to address performance weaknesses in accordance with your
- September 11,1997/ response. We observed that management attention and oversight
were very apparent in the planning and preparation of diving activities, and in the efforts to
effect overall improvement of the radiation protection program. ;While activities and
initiatives associated with the Radiation Protection improvement Plan are still in progress,
the inspector observed good planning and preparation for radiological work activities
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. scheduled for the April 1998 Unit I outage.
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Mr. Charles H. Cruse
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However, based on information developed during the inspection, the NRC has determined
that violations of NRC requirements occurred related to an airborne contamination event in
May 1997 during the Unit 2 refueling outage. These violations are cited in the enclosed
Notice of Violation (Notice) and the circumstances surrounding them are described in detail
in the enclosed inspection report.
Specifically, your staff failed to establish radiological controls for work in the reactor cavity
during cleaning of the reactor flange commensurate with the actual conditions indicated by
the area survey. Accordingly, the work planning and process, personnel respiratory
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protective requirements, and monitoring of personnel for potential exposure to airborne
radioactivity, were not evaluated in view of radiological conditions that were significantly
different than originally anticipated. Further, monitoring of airborne radiological conditions
were ineffective since air sampling was not representative of the workers' breathing zone;
end analysis and determination of the significant concentration of airborne radioactivity, to
which workers were exposed, was substantially delayed by 8 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In addition, the
reactor cavity was not properly posted to identify the hazard when elevated airborne
rcdioactivity concentrations were detected.
These matters were of safety and regulatory significance in light of the high levels of
unevaluated transuranic activity present in the reactor cavity. However, once your staff
realized that significant airborne activity existed, they established effective control of the
areas, and assessed the radiation exposure of the affected personnel. No significant
personnel exposures were identified by your staff; and our review ascertained that
personnel exposure in excess of regulatory requirements was not evident, in this case.
Our review determined that your organization did not effectively survey and evaluate the
rcdiological conditions and revise the radiological protection requirements, accordingly.
These performance errors acted to increase the risk of substantial potentialinternal
exposure of personnel. Therefore, these violations are classified in the aggregate as a
Saverity Level ill problem in accordance with the " General Statement of Policy and
Procedure for NRC Enforcement Actions" (Enforcement Policy),' NUREG-1600.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000
is considered for a Severity Level 111 problem. However, I have been authorized, after
consultation with the Director, Office of Enforcement, to exercise discretion in accordance
with Section Vll.B.6 of the Enforcement Policy to not propose a civil penalty in this case.
The decision to exercise discretion was made because the violations related to the cavity
event occurred approximately one month after the diving event in April 1997, and appear
to be the result of the same fundamental performance deficiencies. In the case of the
diving event, an escalated enforcement action (involving a $176,000 civil penalty) was
issued. Your September 11,1997, letter discussed the diving event and the realization
that a comprehensive assessment of the all aspects of the radiation safety program was
warranted, including evaluation of site and radiation safety procedures. Our inspection
confirmed that broad based corrective actions were underway to improve your radiological
protection program, including review and evaluation of radiation safety procedures, and
previously identified issue reports dealing with radiation safety matters. Additionally, your
stsff initiated development of a Transuranic Activity Assessment and Programmatic Action
Pl:n to address the performance weaknesses revealed by this event and supplement the
broad based corrective actions.
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Mr. Charles H. Cruse
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The' circumstances surrounding these violations, the significance of the issues, and the
need for lasting and effective corrective action were discussed with members of your staff
by. Mr. White on February 20,1998. You acknowledged the seriousness of this matter
and also noted that the circumstances surrounding this event, and the associated incident
reports were included in your_ broad based reviews currently under way.
' You are required to respond to this letter and should follow the instructions specified in the -
enclosed Notice when preparing your response. The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter
and its enclosures, will be placed in the NRC Public Document Room (PDR).
Sincerely,
ORIGINAL SIGNED BY:
Hubert J. Miller
Regional Administrator
Docket Nos. 50-317:50-318
Enclosures:
1.
2.
NRC Combined inspection Report Nos. 50-317/98-03 and 50-318/98-03
cc w/encis:
T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)
R. McLean, Administrator, Nuclear Evaluations
J. Walter, Engineering Division, Public Service Commission of Maryland
K. Burger, Esquire, Maryland People's Counsel
R. Ochs, Maryland Safe Energy Coalition
State of Maryland (2)
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Mr. Charles H. Cruse
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DISTRIBUTION w/encis:
PUBLIC
SECY
CA
L. Callan, EDO
- A. Thadani, DEDE
J. Lieberman, OE (2)
F. Davis, OGC
S. Collins, NRR
R. Zimmerman, NRR
Enforcement Coordinators, RI, Rll, Rlli, RIV
B. Beecher, GPA/PA
G. Caputo, Of
D. Bangart, OSP
H. Bell, OlG
T. Martin, AEOD
OE:Chron
OE:EA
L. Tremper, OC
Nuclear Safety Information Center (NSIC)
NRC Resident inspector - Calvert Cliffs
Region 1 Docket Room (with concurrences)
H. Miller, RA/W. Axelson, DRA
L. Doerflein, DRP
R.Junod,DRP
B. Fewell, ORA
D. Holody, EO
J. Wiggins, DRS
R. Nimitz, DRS
J. White, DRS
C. Miskey, DRS
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Mr. Charles H. Cruse
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Distribution w/encis: (VIA E-MAIL)
B. McCabe, RI EDO Coordinator
R. Zimmerman, ADPR, NRR
J. ' Goldberg, OGC
T. Walker, SES
S. Stewart-- Calvert Cliffs .
S. Bajwa, NRR
A. Dromerick, NRR
M. Campion, RI
D. Screnci, PAO
Inspection Program Branch, NRR (IPAS)
R. Correia, NRR
F. Talbot, NRR
DOCDESK
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DOCUMENT NAME:- G:\\RSB\\NiMITZ\\CC9803. INS
T3 receive a copy of this document,indsets in the ben: *C* = Copy without attachment' enclosure *E' = Copy with attachment / enclosure " N" =
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DATE
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DATE
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