IR 05000317/1997002: Difference between revisions

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{{Adams
{{Adams
| number = ML20140B224
| number = ML20198P927
| issue date = 05/29/1997
| issue date = 11/07/1997
| title = Forwards Insp Repts 50-317/97-02 & 50-318/97-02 on 970302-0412 & Nov.Several Apparent Violations That Are Being Considered for Escalated Enforcement Action IAW General Statement of Policy & Procedure, Were Identified
| title = Ack Receipt of 970911 Ltr & Check for $176,000 in Payment of Civil Penalties Proposed by NRC in 970811 Ltr Re Insp Repts 50-317/97-02 & 50-318/97-02
| author name = Hehl C
| author name = Lieberman J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF ENFORCEMENT (OE)
| addressee name = Cruse C
| addressee name = Cruse C
| addressee affiliation = BALTIMORE GAS & ELECTRIC CO.
| addressee affiliation = BALTIMORE GAS & ELECTRIC CO.
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-317-97-02, 50-317-97-2, 50-318-97-02, 50-318-97-2, EA-97-192, NUDOCS 9706060109
| document report number = 50-317-97-02, 50-317-97-2, 50-318-97-02, 50-318-97-2, EA-97-192, NUDOCS 9711120055
| package number = ML20140B228
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 4
| page count = 2
}}
}}


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        )b y'' -$g  UNITED STATES    pk g  NUCLEAR REGULATORY COMMISSION g  *  WASHINGTON, D.C. 2066H001
.-
% . . . . . ,o November 7, 1997 EA ^7-192 Mr. Charles Vice President - Nuclear Energy Baltimore Gas and Electric Company (BGE)
l l
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, Maryland 20657-4702
May 29, 1997
.
EA No. 97-192
: Mr. Charles i Vice President - Nuclear Energy Baltimore Gas and Electric Company (BGE)
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657 -4702
:
SUBJECT: NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-02  :
AND 50-318/97-02 AND NOTICE OF VIOLATION


==Dear Mr. Cruse:==
==Dear Mr. Cruse:==
,
This will acknowledge receipt of your letter dated September 11,1997, and your check of
This refers to the inspection conducted at the Calvert Cliffs Nuclear Power Plant from j March 2,1997 to April 12,1997 and on April 24,1997. The enclosed report presents the results of the inspection. At the conclusion of the inspection, these findings were  -
$176,000 dollars in payment of the civil penalties proposed by the NRC in a letter dated August 11,1997.
discussed with Mr. Katz and others of your staff.


'
In your response, you admitted all of the violations. With respect to Violation ll.A.2, your response indicated that a comprehensive assessment of the Radiation Safety Program was warranted, including procedure evaluation and organizational process review; and that final corrective actions, as appropriate, would be taken as a result of that effort. We understand that
Based on the results of this inspection, the NRC has determined that a violation of NRC requirements occurred. This violation is cited in the enclosed Notice of Violation (Notice)
" this effort is now complete and that you wiu be prepared to dicuss the outcome, including corrective actions taken or planned, in the management meeting scheduled for November 13, 1997. We also understand that your staff will also be prepared to describe generic improvements in your radiological control program, including High and Very High Radiation Area controls, that resulted from your review and assessment activites.
        '
and the circumstances surrounding the issue are described in detail in Section E1.4 of the enclosed inspection report. The violation concerns inadequate corrective actions following identification of degraded conditions for one of the Unit 1 power operated relief valve block
,
'
valves.
 
>
You are required to respond to the enclosed Notice and should follow the instructions
        !
specified in the Notice when preparing your response. in your response, you should q document the specific actions taken and include any additional actions you plan to prevent recurrence. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. After reviewing your response to the Notice, including your proposed corrective actions and the results of future g inspections, the NRC will determine whether further NRC enforcement action is necessary Ya, to ensure compliance with NRC regulatory requirements.
 
I in addition, several apparent violations were identified that are being considered for So escalated enforcement action in accordance with the " General Statement of Policy and Y Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. As described below, the apparent violations involve the series of problems identified during
'84 fuel handling operations, and control of high radiation area access including the failure to I jg effectively control diving activities in the Unit 2 spent fuel storage pool.
 
The fuel handling problems included the poor material condition of the fuel handling equipment, operation of the refueling equipment contrary to the Technical Specification 060003 h !,hh lh 0FFICIAl. RECORD COPY  IE:01
 
.
.
j Charles requirements, failure to use engineering drawings during troubleshooting, and the failure to follow fuel handling procedures.


On April 3,1997, your staff failed to effectively control diving activities in the Unit 2 spent fuel storage pool and as a result, a diver moved from a comprehensively surveyed area at the south end of the pool to unsurveyed areas at the north end of the pool. The diver sustained an unplanned exposure. Although no exposure in excess of regulatory limits is believed to have occurred, we are concerned that sufficient measures were not employed to provide positive contrnt of this activity which involved very high levels of radiation.
Additionally, we understand that you do not agree that fuel movement continued on March 28, 1997 without a proper evaluation or understanding of the discrepancy in grapple position indicators, as described in Violation Ill.A.3. We acknowledge that the problem had been assesseo and that engineering personnel were preparing a design change to correct the issue after defueling. This was documented in Inspection Report 50-317 (318)/97-02.


Specifically, due to insufficient controls, including inadequate pre-job planning and communication, and lack of positive surveillance, the individual inadvertently came in close proximity to radiation fields in excess of 500 rads per hour.
Notwithstanding, contrary to 10 CFR Part 50, Appendix B, Criterion XVI, the issue, as  j acknowledged in your response, was not promptly corrected after it was discovered.


During the inspection period, we also noted a failure to control access to the Unit 2 containment, a high radiation area, via the emergency airlock, and a failure to properly document the problem in the corrective action system. Additionally, on May 1,1997, a worker performed maintenance for over one hour in a locked high radiation area inside the Unit 2 containment without any dosimetry. Subsequently, on May 4, two workers inadvertently gained access to a high radiation area during the construction of scaffolding in the Unit 2 auxilian :uilding. Although the last two problems occurred outside the inspection period, those issues, in conjunction with the loss of control of the diver, were considered to reflect an apparent breakdown in the applied radiation protection program, specifically the control of high radiation area access at Calvert Cliffs.
ig in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room (PDR).


Accordingly, no Notice of Violation is presently being issued for these inspection findings.
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In addition, please be advised that the number and characterization of apparent violations described in the enclosed inspection report may change as a result of further NRC review.
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Baltimore Gas and Electric Company (BGE)
Your cooperation with us is appreciated.


A predecisional enforcement conference to discuss these apparent violations has been scheduled for June 12,1997 at 10:00 a.m. The decision to hold a predecisional enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. This conference is being held to obtain information to enable the NRC to make an enforcement decision, such as a common understanding of the facts, root causes, missed opportunities to identify the apparent violation sooner, corrective actions, significance of the issues and the need for lasting and effective corrective action. In particular, we expect you to address the apparent lack of effective management oversight in both fuel handling and high radiation area access control, including the May 1 and May 4 high radiation area access problems, as well as the effectiveness of your corrective action processes in identifying and correcting problems in these areas, in addition, the conference is an opportunity for you to point out any errors in our inspection report and for you to provide any information concerning your perspectives on 1) the severity of the violations, 2) the application of the factors that the NRC considers when it determines the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other application of the Enforcement Policy to this case, including the exercise of discretion in accordance with Section Vll.
4-j.
 
You will be advised by separate correspondence of the results of our deliberations on these matters. No response regarding these apparent violations is required at this time.
 
I P
.
I I Charles >
l In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its en::losures, and your response will be placed in the NRC Public Document Room (PDR).


Sincerely,
'
'
            '
BdginalSigntiD1  -
James LDDWU
          '
,  .
James Lieberman, Director  . .
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Sincerely, fs Original Signed by:
~
Larry Nicholson for ,
  .-- Docket Nos. 50-317; 50-318     *  *
Charles W. Hehl, Director i
License Nos. DPR-53; DPR-69      ^'
Division of Reactor Projects i
        [,- J_
Docket / License Nos: 50-317/DPR-53    )
50-318/DPR-69    '
Enclosures:
      )
1. Notice of Violation    '
2. NRC Region I integrated Inspection Report Nos. 50-317/97-02 and 50-318/97-02 cc w/encls:
,
T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)
! R. McLean, Administrator, Nuclear Evaluations l- J. Walter, Engineering Division, Public Service Commission of Maryland l
K. Burger, Esquire, Maryland People's Counsel R. Ochs, Maryland Safe Energy Coalition State of Maryland (2)
i
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      !
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cc: , H. Miller, RI      ,
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Charles Distribution w/encis:
            ,
W. Axelson, DRA      J D. Screnci, PAO      l R. Zimmerman, ADPR, NRR     l J. Goldberg, OGC      l J. Lieberman, OE (OEMAIL)    l D. Holody, EO, RI      l Nuclear Safety Information Center (NSIC)   !
"
PUBLIC      l NRC Resident inspector Region i Docket Room (with concurrences)
  ,
R. Correia, NRR F. Talbot, NRR L. Cunningham, NRR D. Barss, NRR L. Doerflein, DRP      i J. White, DRS T. Moslak, DRP'
   --
R. Junod, DRP Distribution w/ encl: (VIA E-MAIL)    !
DISTRIBUTION:    i*  ,
W. Dean, OEDO (WMD)
'. - ' ...JLieberman, OE        ~
l S. Stewart - Calvert Cliffs    j S. Bajwa, NRR      ,
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A. Dromerick, NRR G. Vissing, NRR M. Campion, RI Inspection Program Branch, NRR (IPAS)
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DOCDESK
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  - TReis, OE    ~
DOCUMENT NAME: G:\ BRANCH 1\CC9702.lR
          '
; To r:ceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =
            "
Copy with attachment / enclosure "N" = No copy OFFICE Rl/DRP n, FK/QRS , Rl/DRP l, Rl/DRP/ h  '
'
. NAME SStewart ,y$ b j$its LDoerflein blT4/ CHehlg "
  - DHolody, RI-        !
DATE 05/27/97 ll #' 05/ /97 05/21/97 05 0 /97 l    OFFICIAL RECORD COPY
  "
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Day File
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,   EA File x
  . _ _
l PUBLIC NUDOCS OEQ RAjRI ,
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YES YES TR7b Hdlieh  JLieberman NO NO 11/ 7 /97 11/ 7 /97 11/- /97 Doc Name: G:\OECASES\97192ACK.TR
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Revision as of 13:59, 20 November 2020

Ack Receipt of 970911 Ltr & Check for $176,000 in Payment of Civil Penalties Proposed by NRC in 970811 Ltr Re Insp Repts 50-317/97-02 & 50-318/97-02
ML20198P927
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 11/07/1997
From: Lieberman J
NRC OFFICE OF ENFORCEMENT (OE)
To: Cruse C
BALTIMORE GAS & ELECTRIC CO.
References
50-317-97-02, 50-317-97-2, 50-318-97-02, 50-318-97-2, EA-97-192, NUDOCS 9711120055
Download: ML20198P927 (2)


Text

. Wrag o

)b y -$g UNITED STATES pk g NUCLEAR REGULATORY COMMISSION g * WASHINGTON, D.C. 2066H001

% . . . . . ,o November 7, 1997 EA ^7-192 Mr. Charles Vice President - Nuclear Energy Baltimore Gas and Electric Company (BGE)

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, Maryland 20657-4702

Dear Mr. Cruse:

This will acknowledge receipt of your letter dated September 11,1997, and your check of

$176,000 dollars in payment of the civil penalties proposed by the NRC in a letter dated August 11,1997.

In your response, you admitted all of the violations. With respect to Violation ll.A.2, your response indicated that a comprehensive assessment of the Radiation Safety Program was warranted, including procedure evaluation and organizational process review; and that final corrective actions, as appropriate, would be taken as a result of that effort. We understand that

" this effort is now complete and that you wiu be prepared to dicuss the outcome, including corrective actions taken or planned, in the management meeting scheduled for November 13, 1997. We also understand that your staff will also be prepared to describe generic improvements in your radiological control program, including High and Very High Radiation Area controls, that resulted from your review and assessment activites.

Additionally, we understand that you do not agree that fuel movement continued on March 28, 1997 without a proper evaluation or understanding of the discrepancy in grapple position indicators, as described in Violation Ill.A.3. We acknowledge that the problem had been assesseo and that engineering personnel were preparing a design change to correct the issue after defueling. This was documented in Inspection Report 50-317 (318)/97-02.

Notwithstanding, contrary to 10 CFR Part 50, Appendix B, Criterion XVI, the issue, as j acknowledged in your response, was not promptly corrected after it was discovered.

ig in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room (PDR).

g 3-9711120055 971107 PDR ADOCK 05000317 G PDR kkl\kkkkkk k

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. . . . .. . . . .

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Baltimore Gas and Electric Company (BGE)

Your cooperation with us is appreciated.

4-j.

Sincerely,

'

'

BdginalSigntiD1 -

James LDDWU

'

, .

James Lieberman, Director . .

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License Nos. DPR-53; DPR-69 ^'

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DISTRIBUTION: i* ,

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YES YES TR7b Hdlieh JLieberman NO NO 11/ 7 /97 11/ 7 /97 11/- /97 Doc Name: G:\OECASES\97192ACK.TR

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