ML20235S260
| ML20235S260 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/16/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8903070046 | |
| Download: ML20235S260 (2) | |
See also: IR 05000317/1988020
Text
P.
r,g
gy
-
,
l
'
,
j
,
(e[-
e.**
.
,
'
'
9.;
v
~
.
- y,
n
j
' FEB 161989
-l
"
'
,
,
d
&
hetNo.# 50-317 and 50-318'
.
<
D
,
I
. ..
(
4>
'. Baltimore Gas and Electric Company
1
4
fATTN: JMr. J. A. - Tiernan
'
3
p+
'Vic'e President-
~ g
.
. Nuclear'Energyf
j
s . Calvert Cliffs Nuclear Power Plant
i
'
,
w.
,o
.MD Rts 2,&'4','P.O. Box 1535
i
"
,
j
'1 ..Lusby, Maryland 20657
3,
w
g
(Gentlemen:
1
CSubject: Inspection Nos.
50-317/88-20; 50-318/88-20
1
>
m
-1
.We have received'your letter, dated October 19, 1988, in'responsettoour
n
,
letter, dated. September 9, 1988.
In your' letter, you agree that the
.
sinadequate pre-job: survey' described.in NRC. Inspection Report 50-317/88-20;.
4
.
,50-318/88-20 and.the accompanying Notice of Violation constitutes a1 violation
!
Lof :10:CFR 20.201, " Survey". You also state your. belief that the violation
l
,t
- qualifie's' for enforcement discretion per 10 CFR 2 Appendix C, V.G.
l
,
. Consequently, you.ask for a retraction of the Notice of Violation.
'
The applicability of.. enforcement discretion per 10 CFR 2 Appendix C was
j
f originally 1 evaluated during' the subject inspection and is discussed in:the-
it
D;
inspection report. '.Your actions to mitigate'the violation were not considered
j
prompt and aggressive to prevent recurrence since (1) findings of your Quality
y
,
Assurance. auditor-were not accepted until six weeks after the incident when the
<1
-Calvert Cliffs Report.was submitted to the Plant Safety Onsite Review
Committee, (2) briefing of your_ technicians co'ncerning the incident!did'not
.
occur until the NRC performed it's inspection on-August 17-19,'1988, approxi-
,mately eight weeks after the1 incident, and (3) interviews of the maintenance
j
workers in question were not. conducted by your Radiation Safety staff as of
al
!
August 19,L1988.
We have reviewed the information provided in your response to the Notice of
Violation. We feel no new information is provided which would cause us to
j
.
revise our original conclusion.
Your assertion that technicians were briefed
the day following the incident is not substantiated by documentation and
4
. conflicts with information given to our inspectors by your staff during the
4
inspection. Consequently, the Notice of Violation will not be retracted.
l
~Your letter also informs us of additional corrective actions taken subsequent
to the. subject NRC inspection. These actions will be examined during a future
- inspection of your licensed program.
!
f(
'8903'070046 890216
M
g~
,g -
)
ADOCK 05000317g
G
PNV
3
OFFICIAL RECORD COPY
RL CALVERT 88-20 - 0001.0.0
02/06/89
,
4
_
__ a
-__ _ _ ___
D
__
_.
_
_
= - _ _ _
_
._ __ _
_
--
-
-
_--
.'h i -. (;l
,4
.
~ d -
-
<
' .
v
FEB 16.1989
Baltimore Gas and
<2
. Electric Company
Your;cooperat' ion.with us is appreciated.
Sincerely,
Original Signed By':
William V. Johnston
.for Stewart D. Ebneter, Director-
Division of Radiation-Safety -
and Safeguards
L
cc w/ enc 1:
' W. J. Lippold, General Supervisor, Technical Services. Engineering
T. Magette, Administrator, Nuclear Evaluations
Is
Public Document Room (PDR)
Local Public Document Room -(LPDR)
,
' Nuclear Safety-Information Center (NSIC)
NRC Resident Inspector
State'of Maryland (2)
~
,
bec w/ enc 1:
.
..
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1),
'
H
'
.L. Tripp- DRP
,
'"..
D. Limroth, DRP
-
.
S.'McNeil, NRR
R. Bores, DRSS.
.
..
PA0 (14) SALP. Reports Only
"
J. Wiggins,.DRP
P. Wilson, DRP-
,,g
- RI:DRSS
RI:DRSS-
RI:DRSS
'RI:
S
R
S
A Weadock/mk
Loesch
Shanbaky
Bellamy
Ebneter
~v
sm
ont
+3
02/ 8 /89
03./ 8 /89
01////89
02/)d(/89
02//[/89
0FFICIAL RECORD COPY
RL CALVERT 88-20 - 0001.1.0
02/06/89
. _ _ _ _
_ _ _ - - - _ .
_ _ _ _ .
. _ _ _ _ - _ _ _ - _ _ - _ _ _ _ _ - _ _ _ _ _ _
--
__
- m ves n u e 6 BlPlP s
P02
!
l'
-
- ..
.
.
,
' *
f.
.-
.;
!
- *'
i
BALTIMORE
GAS AND j
! M
ELECT
N .,
[RIC
'f
CHARLES CENTER P. O BOX 1475 * BALTIMOAE.MANY
Josten A.7dERNAN
Vses Passeggest
Nwc6sas Ents0F
I
.
October 19, 1988
""
U. S. Nuclear Kegulatory Commission
\\
Washington, DC 20353
ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant
<
Unit Nos.~ l & 2: Docket Nos.
Combined Insrection Report No.50-317 & 50-38t
50-317/88-20: 30-318/88-20
REFERENCE:
(a) Letter from Mr. R. R. Bellamy (NRC) to Mr
,
dated September 9,1988, same subject
. J. A. Tiernan (BG&E),
d.
Gentietnen:
This is m response to Reference (a) and the exit
Calvert Cliffs. Appendix A is a Notice of Violation of 10 CFR 2
interview held on August 19, 1988, at
Enclosure (1) provides a response to the Notice of Violation
Reference (a). Our response includes a request that the issuan
Violation be retracted. Information is provided in Enclosure (J)
adequate to justify retraction
of the Notice of Violation.
We appreciate your assessment and constructive criticism of
Program and welcome your. comtnents and insights on this respon
in our quest for excellence
at Calvert Cliffs. Should you havese as we seek to improve
regarding this matter, we will be pleased to discuss them with yo
any further questions
u.
Very truly yours,
,
JAT/CDS/ dim
Enclosure
'
.
,
'
-
gewat
-
-
_ _ _ _ _
_
_ _ _ _ _ _ _ _ _ _
__-
_ _ _ _ _ - _ _ - _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ - _ _
',
.
.
.
.
'
,
-
301 586 2628
NOU 10 '88 11:30
NRC cplVERT CLIFFS
P03
.
Document Control Desk
October 19, 1933
Page 2
,
,
L.
.
..
D. A. Brune, Esquire
cc:
J. E.
Filberg, Esquire
R. A. Capra, NRC
$. A. McNeil. NRC -
W. 7. Russell, NRC
D. C. Trimble/V. L. Pritchett, NRC
T. Magette, DNR
.
.
..
.
a
w
, " " -
301.586)2628.
.
.
.. -
x -
lHO@l01'8811:30
E
'
E
NRC CALVERT CLIFFS
PO4
.
..
"
-ENCLOSURE (ti
.
RESPONSE TO APPENDIXA-
OF
NRC INSPECDON
REPORT
,M
50-317/88-20, 50-318/88-20
Appendix A of NRC Inspection Report
,
in thst an inadequate pre-job ~ survey was perform
50-317/88 20 50 3- 18/88-20
'
-
is a Notice of. Violation
at Calvert Cliffs "Uniteventr in Reference .
agree. that the
e
- Survey," as stated ininadequate pre-job . survey
constitutes
,
1. We - also
the Notice of Violation.
s ' violation of.10 CFR - 20.201,
We believe, however, . that
- 10 CFR 2 Appendix . C V.G. and thusthe violation
qualifies for
enforcement. - discretion
issue a notice of violation forViolation.10 CFR 2 Appendix C. V.G
per
, in part, that
a violation that
the 'NRC will not 8enerally.
It was identified by the licensee;
meets all of the following. criterix -
a.
,
b.
It fits Severity Level IV or ' V;
c.
It was reported, if required;.
d.
It was or will be correcte1 including measures to prevent
within a reasonable time; and '
e.
It
recurrence,
was not a violation that could
<
prevented by the ' licensee's
reasonably be expected to have been
corrective action for a previous violation."
-
The NRC inspector indicated that "the
discretion as a licensee identified violation as pro id dviolation potentially
but that- * mitigation of the violation
qualifies for enforcement
for in 10 CFR 2, Appendix
C."
v e
' indicates that
was not
that prompt . and aggreisive action to preventthe' reason for - the m
appropriate."
The inspection
report
.
n not
We believe that
recurrence was not ~ initiated.being appropriate wa
fashion to presentpertinent ' corrective and
for enforcement discretion perrecurrence of the eventpreventive measures
were taken in a prompt
and that the violation did, in fact,
10 CFR Appendix C, V.G. To support this conclu i
furnish
the information provided below.
qualify
the issuance of the Notice of Violation be r t
Based upon this. information,
s on, we
e racted.
we request that
Upon discovery that
the workers had been exposed to higher than
.
dose rates, the Radiation
Safety (RS) technician who had performed the
initial survey immediately
expected
" hot spot * four
re-surveyed
the area as a High Radiation Area Ex lto five feet from the act
. He then re-posted
visor of the situation. A more thorough surc usion Area and notified his super-
vey wa$ subsequently performed.
Later
that same day, the
having performed
RS technician
was verbally counselled for not
un adequate
with all RS technicians beginning with their dailycorr
pre-job . survey at the valve alley. All
ent
on June 22, 1988.
were discussed
however, which may have lead the NRC inspNo formal documenta
scussions were made,
RS technicians
the week of his inspection on Augustbriefed. concerning ector to the conclus
were not
the details of the event
19, 1988.
until
~
__
_ _ , . _ . , - - - - - -
_
._ -
.
p 1,.y.. :..-
.
3.
.
>
,
-
.
4
301 586 2628
HOV 10 '88 11:31
NRC CAlVERT CLIFFS
P05
ENCLOSURE fi1
.-
RESPONSE TO APPENDIX A OF
NRC INSPECTION
REPORT 50-317/88-20; 50-318/88-20
p
,
..
,
L
. . - .
This incident prompted the Radiation Safety Section to request that a
formal investigation of the incident be' performed. The results . of this
investigation
identified
the
contributing
causes
of
the
incident
and
suggested corrective measures to prevent recurrence. The results were
presented to the Plant Operations and Safety Review Committee (POSRC),
which recommended to the Manager-Calvert Cliffs Nuclear Power Plant that
the incident, and the - lessons learned from it, be reviewed with all RS
technicians during their normal required training courses and that this
training and all - thee who attended it be formally documented. All RS
were appeh?d of the incident through this training vehicle by
,
M, technicians
t
19, _1988. This was the first formally documented case of RS
h' August
'
technicians being apprised of the incident.
As stated in Reference (a), there - was a difference of opinion between the
Radiation Safety Section and the auditor who performed the formal investi-
gation. This difference opinion centered around the issue of whether or
not it was possible for the RS technician to perform a proper survey in
t
this particular situation without crossing the step-off pad and proceeding
l
into the valve alley. Radiation Safety personnel argued that a proper
survey could hase been done with a telescoping instrument which is
i
!
available on site. There was never any disagreernent between the two
parties that an inadequate survey had been performed in this particular
case.
..
We believe that the ' corrective actions noted above were prompt and aggressive, and were
sufficient
to
preclude
recurrence
of
the
incident.
No
further
incidences
of
performance of inadequate surveys have since occurred at Calvert Cliffs.
Additional correctise actions, which have been taken since the N R C exit meeting on
August 19, 1988, are as follows:
The General Orientation Training sy!!abus has been modified to include a
o
discussion of the incident.
o
Requalification training will include a discussion of the event in i'.s 1989
L
training cycle.
-
During a review of the Special Work Permit (SWP), we determined that the
l
o
SWP used by the workers may have contributed to the incident. What
constitutes a " routine * (blanket) SWP has been more tightly defined. The
SWP form has been revised to include limits on area radiation do$c rates
and individual dose. As a result of this change, fewer routine SWPs will
be issued effective September 6, 1988.
. _ _ _
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
_