ML20217P895
| ML20217P895 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/29/1998 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| References | |
| CAL-1-98-06, CAL-1-98-6, NUDOCS 9805070124 | |
| Download: ML20217P895 (5) | |
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,[ h April 29, 1998 CAL No.1-98-006 Mr. Charles,H. Cruse Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702
SUBJECT:
CONFIRMATORY ACTION LETTER
Dear Mr. Cruse:
On August 11,1997, NRC issued a Notice of Violation and Proposed imposition of Civil Penalties (i.e., a Severity Level ll violation and associated civil penalty of $176,000),as a result of significant deficiencies in the performance of radiological controls implemented for
' diving activities in the Unit 2 Spent Fuel Pool on April 3,1997, which resulted in substantial potential for personnel exposure in excess of regulatory limits. Your response, j
dated September 11,1997, identified corrective actions to affect comprehsosive radiation i
protection improvement. Since then, our staff has continued to review your corrective actions and improvement efforts. Our subsequent inspections and reviews indicated apparent progress in program improvement. On April 9,1998, you informed us that a worker received unplanned radiation exposure while engaged in radiological work in the Unit 1 Reactor Vessel Annulus, a high radiation area with dose rates as high as 6000 miilirem per hour. The preliminary findings of your Significant incident Findings Team (SIFT) and our own inspection effort revealed significant performance deficiencies, including: (1) the senior radiation protection technician, assigned to directly monitor the worker's teledosimetry, failed to control the individual's radiation exposure to the limits specified by your procedursis; (2) a senior radiation protection technician incorrectly calculated the worker's stay-time, resulting in a non-conservative estimate of time available for the worker to remain in the high radiation area; (3) and radiation protection supervisory personnel did not attend pre-job briefings or picvide oversight of the actual work to assure that applicable radiation safety controla were understood and implemented. These performance problems occurred, even though your organization considered tasks in the
[
Reactor Vessel Annulus to be " higher-risk" radiological work, requiring comprehensive planning, preparation, management oversight, and direct radiological control. While no regulatory limit was exceeded in this case, the continuing occurrence of radiological control related problems suggest that your previous corrective actions have not been effective in /
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7 resolving deficiencies and weaknesses in this area.
/ y
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In your letter dated April 27,1998, Actions to improve Radiation Safety During the Unit i Refueling Outage, you described immediate and long-term actions to address the weaknesses identified by your review. We will monitor the effectiveness of these actions through our inspection program.
9905070124 990429 PDR ADOCK 05000317 P
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Mr. Charles H. Cruse 2
Notwithstanding, pursuant to a telephone discussion on April 29,1998, between yourself and Mr. James T. Wiggins, Director, Division of Reactor Safety, it is our understanding that you willimmediately clarify and supplement the actions characterized in your April 27, 1998 letter, as described below:
A.
Relative to the current Unit 1 outage:
1.
For radiological work that is determined to be " higher risk," department supervision from the task organization and the radiation protection 1
organization will provide periodic oversight of pre-job planning activities sufficient to assure that appropriate radiation safety controls are established and integrated with the task, and attend pre-job briefing efforts to assure that radiation safety control requirements are effectively communicated to
. personnel responsible for the conduct and control of the work activity.
2.
For radiological work that is determined to be " higher risk," lead or supervisory personnel from the task organization and the radiation protection organization will provide direct oversight of field activities whenever actual work is being conducted to assure that planned radiation safety controls are effectively established and implemented.
3.
You will establish and implement a planned series of surveillances or audits by either the quality assurance organization or other organizations, independent of the task organization and radiation safety organization, to determine the effectiveness of the actions described in items A.1 and A.2, l
above.
B.
R9lative to general radiation protection improvement:
1.
During the outage, you will engage the services of an independent assessor to assess the quality and performance of ongoing radiological control activities.
2.
By no later than June 26,1998, you willinform this officc of the findings of the assessment efforts, as described in items A.3 and B.1 ai,sve, and actions taken or planned in response.
3.
You will review and assess previous performance deficiencies involving radiological control imple:aentation to validate your determination of root cause and assess the effectiveness of corrective actions; and by June 26, 1998, provide your assessment of why previous corrective actions were not effective in preventing the deficient radiological control performance relative to the Reactor Vessel Annulus work activities on April 8 and 9,1998,-
including measures, taken or planned, to improve corrective action effectiveness, j
i
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Mr. Charles H. Cruse 3
- None of these commitments shall preclude you from taking actions as necessary to ensure :
~
. the health and safety of workers 'and the public, protect the environment, and comply with applicable regulatory requirements.
Pursuant to Section 182 of the Atomic Energy Act,42 U.S.C. 2232, you are required to:
1)
Notify me immediately if your understanding differs from that set forth above; 2)
Notify me if for any reason you cannot complete the actions within the specified schedule and advise me, in writing, of your modified schedule in advance of the change; and 3)
Notify me, in writing, when you have completed the actions addressed in this Confirmatory Action Letter.
Issuance of this Confirmatory Action Letter does not preclude issuance of an order formalizing the above commitmants or requiring other actions on the part of the licensee; nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. Failure to take the -
actions addressed in this Confirmatory Action Letter may result in enforcement action.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your response'will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, if personal privacy or proprietary information is necessary to provide an acceptable response, please provide a -
bracketed copy of your response that identifies the information that should be protected.
and a redacted copy of your response that deletes such information. If you request withholding of such material, you mua.1 specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of
. personal privacy or provide the information required by 10 CFR 2.790(b) to supvort a request for withholding confidential commercial or financial information). If se teguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Sincerely, ORIGINAL SIGNED BY:
WILLIAM L. AXELSON K)R Hubert J. Miller Regional Administrator Region i Docket Nos. 50-317;50-3*i8 License Nos.' DPR-53; DPR-69
Mr. Charles H. Cruse 4
- cc:
T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)
R. McLean, Administrator,. Nuclear 5 Wluations J. Walter, Engineering Division, Public dervice Commission of Maryland K. Burger, Esquire, Maryland People's Counsel R. Ochs, Maryland Safe Energy Coalition State of Maryland (2) l f
\\
Mr. Charles H. Cruse 5
Distribution:
Nuclear Safety Information Center (NSIC)
PUBLIC NRC Resident inspector Region I Docket Room (with concurrences)
L. Doerflein, DRP R.Junod,DRP DRS File Distribution: (VIA E-MAIL)
B. McCabe, RI EDO Coordinator S. Stewart - Calvert Cliffs S. Bajwa, NRR A. Dromerick, NRR M. Campion, ORA D. Screnci, PAO Inspection Program Branch, NRR (IPAS)
DOCDESK DOCUMENT NAME: G:\\RSB\\ WHITE \\CC-CAL.JRW TJ receive a copy of this document, Indicate in the box:
"C" = Copy without attachment / enclosure "E" = Copy with attawanent/ enclosure "N" = No copy OFFICE Rl/DRJ,tg lE Rl/DRS lE Rl/DRP, E Rl/ORAjf() lE Rl/ ORA lE NAME J)Myfg/O JWigginsy CHe @
DHolodt f,f BFewell DATE 0 41 @ 8 04/f /98 W 04/p/98 04/ja/98 '
04/ /98 OFFICE Rl/D}ff;f E Rl/R A /jf f g
NAME WA$T/s'on HMiW L f(V DATE 04M98 04pf/98 04/ /98 04/ /98 04/ /98 OFFICIAL RECORD COPY
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