ML20217H926
| ML20217H926 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/27/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9804300121 | |
| Download: ML20217H926 (4) | |
Text
CII ARI.ES II. CRUSE Minore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Miuyland 20657 410 495-4455 April 27,1998 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit No.1; Docket No. 50-317 Actions to Imorove Radiation Safety During the Unit 1 Refueling Outage As a result of two radiation protection (RP) events on April 9,1998, I have taken actions to address concerns and to ensure the remainder of the Unit 1 Refueling Outage is conducted safely. This issue is receiving the highest attention and action by Calvert Cliffs Nuclear Power Plant (CCNPP) senior management. I have established a top level management review board, consisting of the Superintendent
- Maintenance, the RP Manager, and the General Supervisor - Radiation Safety, to review all planned outage RP higher risk work conducted at CCNPP, and to recommend to the Plant General Manager (PGM) that the work will proceed safely. The five Calvert Cliffs Managers and I will make personal assessments of radiologically-controlled area (RCA) work cn a regular basis to help assure that our expectations for the safe conduct of the work are communicated and met. The PGM will report regularly to me on the health of RP Program. In addition, I have personally made it clear to the Managers and key Superintendents that that they will hold people accountable for Special Work Permit (SWP) compliance.
I am committed to ensudng that all radiation area work is conducted safely.
A Significant Incident Finding Team (SIFT) was assigned to perform an investigation, determine causal factors, and recommend corrective actions for the April 9 events. Immediate corrective actions for the events are complete. Near-term actions are being implemented. Long-term corrective actions are being planned to address the causal factors. I informed you of these actions in a telephone conference held on April 23,1998 with Nuclear Regulatory Commission Region I staff. This letter summarizes those actions.
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SUMMARY
OF IMMEDIATE ACTIONS On April 9,1998, a technician received a radiation exposure, which exceeded his SWP limit, while working in the Unit 1 Reactor Vessel Annulus. The PGM immediately stopped work in the Unit 1
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Reactor Vessel Annulus. In addition, the PGM required the Superintendent - Maintenance, the RP Manager, and the General Supervisor - Radiation Safety to jointly agree that work was planned safely prior to moving ahead with specific RP higher risk work. The PGM also stopped use of the remote alarming dosimetry system associated with the event until concerns with its operation were resolved.
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Document Control Desk April 27,1998 Page 2 '
Because of its significance, we declared th:: event a Nuclear Plant Incident - our most significant event
- category-and established the SIFT to determine the causal factors, recommend corrective actions, and make recommendations to prevent recurrence of the event. During the SIFT process, we discovered a previous event..Other workers entered the Unit 1 Reactor Vessel Annulus earlier on April 9,1998, without wearing alarming dosimetry as required by the SWP. The SIFT is continuing to investigate these
- two events.
Preliminary investigations indicate weeknesses in our application of radiation safety fundamentals:
- 1. Radiation Safety personnel actions for worker safety in RCAs were not effective;
- 2. Stay times were miscalculated; and
- 3. Line personnel were not effective in ensuring their personal radiation protection.
A site-wide safety break was conducted on April 16,1998, to discuss the preliminary findings of the SIFT with the entire site population.
Personnel involved in these events included contractor senior radiation safety technicians. While we are responsible for the conduct of our contractors, I have communicated with senior management of all the major contractors on site about these events. With regard to contractors involved in this issue, I directed their senior management to assess and take corrective actions for these events.
SUMMARY
OF SHORT-TERM ACTIONS In an April 24,1998 Calven Cliffs liand-Out,'I provided direction to all site personnel that we must significantly raise our awareness of our responsibilities for radiation safety. Under no circumstances should any of us perform a task without completely understanding every aspect of the job and safety requirements.
Prior to the performance of planned outage RP higher risk work, the top level management review board will recommend to the PGM that the work will proceed safely. The recommendation will include clearly specified line and radiation safety ownership and other imponant safety criteria.
During integrated pre-job briefings, we have identified opportunities to improve the pre-job planning and training for RP higher risk jobs. We are handling these items in pre-job briefings immediately prior to conduct of the job. We are establishing multi-disciplinary teams to review RP higher risk jobs and improve planning and training for them. The teams will involve stakeholders associated with each job.
- The goal of the reviews is to ensure planning and training for each RP higher risk job is conducted in advance of the pre-job briefing. In the interim, prior to achieving this goal, we will use integrated pre-job briefings with Radiation Safety and line organization supervisory oversight to ensure readiness to accomplish the RP higher risk work.
We have ensured that Radiation Safety Supervisors are informed of all'RP higher risk work. All RP higher risk work will be overseen by Baltimore Gas and Electric Company Radiation Safety and line personnel. We are taking actions to strengthen oversight of contractor radiation safety technic *ans during the current refueling outage.
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Docum:nt Control Desk April 27,1998 Page 3 1
For Radiation Safety supervisors, we are developing supervisory observation tools. similar to those used in Nuclear Operations, to improve performance in field observations of work.
We implemented a requirement for peer checks and supervisory review for a new form to standardize stay time calculations. We are reviewing SWPs to assure that adequate radiation exposure margin exists to accomplish work safely and maintain ALARA fas low as reasonably achievable).
We are reviewing at briefings for line workers the required dosimetry and its proper location for RP higher risk work. We have improved the ability to hear alarming dosimeters or will take compensatory A standard form is in use to display the correct locations of required special personal measures.
dosimetry. We have revised the maintenance pre-job brief form to prompt worker verification of stay time, dosimetry requirements, and alarm audibility prior to commencing work.
To address safe work in all RCAs at CCNPP, we are conducting training for all personnel with RCA access on these events and management expectations for worker performance in any RCA.
We are retaining health physics and RP manager consultants to advise the PGM. The consultants will regularly brief the Vice President -Nuclear Energy on the performance of the site RP Program.
An Institute of Nuclear Power Operations assist visit will be conducted in RP starting April 27,1998, to examine our site RP Program.
SUMMARY
OF LONG-TERM ACTIONS
'Ihe SIFT process will be completed and causal factors identified. These will lead to long-term corrective actions. Although the long-term corrective actions have not been formalized, we plan to address identified weaknesses in the performance of radiological work at CCNPP.
We are dedicated to assuring the personal safety of workers in the RCA. We have been implementing our site Radiation Protection Improvement Plan. The plan is comprised of four tasks: Improve.
management oversight and communications; integrate RP into work processes; improve site RP knowledge; and, improve RP assessment. We believe the principles are sound. However, we will assess the implementation of the plan and take appropriate corrective actions. In addition, we intend to capture all long-term corrective actions under our site Radiation Protection Improvement Plan.
We plan to strengthen the performance of Radiation Safety supervisors and work leaders by conducting leadership training. Also, we plan to conduct advanced radiation worker training for maintenance workers.
-We plan to review processes used to conduct work in the RCA in order to assure appropriate attention to important job steps and simplify steps where possible. This review will include line workers and supervision.
We are conducting an effectiveness review of RP higher risk work preparations. We plan to improve the incorporation of our site and industry RP experience intojob planning.
Document Control Desk April 27,1998 i
Page 4 The Nuclear Performance Assessment Department will perform an effectiveness review of corrective actions.
As we implement these actions, I will keep you informed of any significant findings and our progress in dealing with these issues. Upon final development of causal factors, the long-term actions may supersede immediate and shon-term corrective actions identified above.
Personnel safety is my highest priority.
Should you have questions regarding this matter, I will be pleased to discuss them with you.
Very truly yours,
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CHC/JMO/ dim cc:
R. S. Fleishman, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC Director, Project Directorate I-1, NRC R. I. McLean, DNR A. W. Dromerick, NRC J. H. Walter, PSC
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