ML20246J949
| ML20246J949 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/07/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8907170485 | |
| Download: ML20246J949 (3) | |
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- o BALTI M O RE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475. BALTIMORE, MARYLAND 2t203 GEORGE C. CREEL Vict Patsment nucle AR Esd.nov (300 880-4465 July 7,1989 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-31"' & 50-318 Reply to Notice of Violation (luspection Report Nos. 50-317/89-10; 50-318/89-10)
REFERENCE:
(a) Letter from Mr.
R.
R.
Bellamy (NRC) to Mr.
G.
C.
Creel (BG&E), dated June 8,1989, same subject Gentlemen:
As requested in Reference (a), we are providing the foUowing response to the subject Notice of Violation. Two violations were combined into one Severity Level IV violation against our Radiological Protection Program.
The violation identified two deficiencies within the Radiological Protection Program, a.
Failure to resiew radiological surveys; and, b.
Failure to perform ALARA Field Services installation inspections.
1.
Corrective Steps._T$en and_Ef2@s Achjp.ynd a.
The inspector identified four Special Work Permit (SWP)
- packages, Nos.89-829, 89-2303, 89-2305, and 89-2309, vhere radiological surveys were 1
not reviewed properly by the Supervisor Radiation Control Operations (or his designee) for completeness and/or for correct and appropriate data.
l This is contrary to the requirements set forth in Radiation Safety J
Procedure (RSP) 1-101, " Radiological Surveys," section 3.7.3.
Immediately upon notification (May 10, 1989), an in-depth audit was initiated to review all outage SWP packages to determine procedural compliance (audit was completed May 16, 1989). Additional examples of similar deficiencies were found. In addition, the AGS-RCS met with all Radiation Safety Supervisors and Radiation Safety Technicians to clarify SOS 8907170485 890707
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PDR ADOCK 05000317
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PNV j
e, Document Control Desk July 7,1989 Page 2 l
1 and emphasize strict procedural compliance in the performance and review of radiological surnys. This was documented via a Calvert Cliffs Memorandum (CCTM 89-RS-35) dated May 9,1989. Subsequently, the GS-RS personally met with the Radiation Safety Supervisors to reinforce the fact that they and their technicir M are personally accountable for conformance to procedures.
b.
The inspector identified three SWP packages, Nos. 89-2038, 89-2501, and 89-2503, where failures to perform ALARA Field Services Installation inspections at the frequency stated on the ALARA Field Services Worksheet (RSP l-202-1) were evident. This is contrary to the requirements set forth in RSP l-202, "ALARA Field Services," section 6.1.3 and 6.3.
Immediately upon notification (May 10, 1989), an audit of all outage SWP packages requiring ALARA Field Services insta'llation inspections was conducted with emphasis placed on field installation inspection frequencies (audit completed May 15, 1989). Additional examples of similar deficien-cies were found. In addition, r.n interim inspection tracking mechanism was put in place to ensure / enhance procedural compliance for ongoing tasks (effective May 22, 1989) until a formal tracking mechanism can be established within the procedure.
2.
Corrective Stem Which Will be Taken to Avoid Further Violations a.
The outage SWP audit highlighted weaknesses with two RSPs that govern the Radiological Survey Program. Specifically, RSP l-101, " Radiological Survey Programs," provides vague direction when requiring certain surveys to be conducted (e.g., beta exposure rates, alpha loose surface contamina-tion determinations, and large area smear determinations), and in the administration and use of Job Coverage Data /Re-survey Records (JCD/RR).
In addition, RSP l-106, "Special Work Permit Administration," currently does not formally include the JCD'RR, nor does it allow flexibility in the assignment of surveys based on changes in job status.
Both of these procedures, RSP l-101 and 1-106, are currently being revised to address / resolve these deficiencies.
b.
The RSP that governs ALARA Field Services installation inspections, RSP l-202, A L A R A Field Services," t:urrently does not provide a formal tracking mechanism to ensure that all required inspections are performed.
This procedure currently is being revised to provide a formal tracking mechanism for ALARA Field Serviets installation inspections.
3.
Date When Full Comoliance Will be AchievecJ.
Procedural revisions for RSPs 1-101,
" Radiological Surveys,"
l-106, "Special Work Permit Administration," and 1-202,,
"A L AR A Field Services" are currently being performed and will be implemented by July 31, 1989.
s
. g Document Control Desi:
July Y,1989
~ Page 3 Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
.n.
l
(
l GCC/ PSF / dim i
ec:
D. A. Brune, Esquire J
E.
Silberg, Esquire R. A.Capra,NRC S. A. McNeil, NRC W. T. Russell, NRC H. Eichenholz/V L. Pritchett, NRC T. Magette, DNR l
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