ML20199D132

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insps 50-317/86-05 & 50-318/86-05.Retracts Item a Re Dosimetry & Respiratory Protection

ML20199D132
Person / Time
Site:	Calvert Cliffs
Issue date:	06/13/1986
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 8606190348
Download: ML20199D132 (2)

See also: IR 05000317/1986005

Text

{{#Wiki_filter:.. 4 .. O JUN 131986 . - License Nos. DPR-53 ' Docket Nos. 50-317 50-318 DPR-69 Baltimore Gas and Electric Company ATTN: Mr. J. A. Tiernan Vice President Nuclear ~ Energy P.O. Box 1475 Baltimore, Maryland 21203 Gentlemen: -Subject: Inspection.Nos. 50-317/86-05 and 50-318/86-05 This refers to your letter dated May 17, 1986, in response to our letter dated April.17, 1986. ' Thank you for. informing us of.the corrective and preventive actions documented ' in your letter. These actions will be examined .during a future inspection of your. licensed program. With regard to Item A, we have; reviewed your. audit report, dated April '17, ~1986, for -the- Quality Assurance Audit -QAP-8 (Dosimetry and Respiratory-

Protection) performed February 11 through March 17, 1986. This audit includes

Finding Number 86-09-02, failure to have an approved procedure for operation of the standup whole body counter. Although this audit was ongoing during our inspection of March 3-7, 1986, it was not documented until after completion of -our inspection. Discussion by the NRC Resident Inspector with the QA auditor i on May 28, 1986, indicated that this item was identified prior to the- begin- ning of our inspection. Therefore, Item A meets all of the requirements of 10 CFR 2,' Appendix C, for a violation for which -the NRC will not generally issue: - a notice of violation: -(1) it was identified by the licensee; (2) it fits in: -Severity Level IV or V; (3)-it was reported, if required; (4) it was or will be corrected, -including measures to prevent recurrence, within a reasonable time; and (5) it was not a violation that could-reasonably be expected to have .been prevented _ by the licensee's corrective action for a previous violation. Item A is retracted. We will modify.our records accordingly. Your cooperation with us is appreciated. Sincerely, 'origfrel Signed Dpt Th0Cas T. Martin . - Thomas T. Martin, Director. 8606190348 860613 Division of Radiation Safety ADOCK0500g7 and Safeguards DR [[k ' ' 0FFICIAL' RECORD COPY . - . . . . .

$- Baltimore Gas 2 i and Electric Company cc : M. Bowman, General Supervisor, Technical Services Engineering Thomas Magette, Administrator, Nuclear Evaluations Daniel Latham, Director, Security Services (Safeguards Only) Norman J. Bowmaker, Vice President, General Services (Safeguards Only) Public Document Room (PDR) Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of Maryland (2) bec : Region I Docket Room (with concurrences) Management Assistant, DRMA (w/o encl) DRP Section Chief M. McBride, RI, Pilgrira T. Kenny, SRI, Salem D. Jaffe, LPM, NRR k 41 S h [RSS:RI

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,. . . - a, . BALTIMORE GAS AND ELECTRIC 3 CHARLES CENTER P. O. BOX 1475 BALTIMORE MARYLAND 21203 JOSEPH A.TIERNAN VicE PREslOENT NUCLEAR ENEROY May 17,1986 U. S. Nuclear Regulatory Commission License Nos. DPR-53 Region I DPR-69 631 Park Avenue Docket Nos. 50-317 King of Prussia, PA 19406 50-318 ATTENTION: Mr. Thomas T. Martin, Director Division of Radiation Safety and Safeguards Gentlemen: This refers to inspection Report 50-317/86-05 and 50-318/86-05, which transmitted two items of apparent noncompliance with NRC requirements. Enclosure (1) to this letter is a written statement in reply to those items noted in your letter of April 17, 1986. . Should you have further questions regarding this reply, we will be pleased to discuss them ! with you. l Very truly yours, ' i f l JAT/SRC/ dim Enclosure cc: D. A. Brune, Esquire i J. E. Silberg, Esquire ' D. H. Jaffe, NRC T. Foley, NRC l , b h0hk~7C71Q~ - - -

. ., . . . - - ENCLOSURE (1) l REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/86-05; 50-318/86-05 ITEM A At the time of the inspection, the computerized chest counter was in use to supplement approved procedures for identifying personnel having potential internal contamination. The chest counter identifies those personnel whose counts are statistically greater than background levels and instructs the operator to perform, as necessary, whole body counts using an approved procedure in accordance with Technical Specification 6.8.1.a. The chest counter was not used to perform analytical measurements to assess internal intakes. This use of a draft procedure was identified as a deficiency by the Baltimore Gas and Electric (BG&E) Company prior to the inspection during a recent Quality Assurance audit. This fact was communicated by Mr. E. H. Roach of our staff, to Mr. J. J. Kottan of your staff, prior to the exit meeting. A commitment was made to our internal Quality Assurance organization prior to the NRC inspection to formalize the procedure for the operation of the chest counter. This draf t procedure will be approved and implemented by June 1,1986. Because this is a licensee-identified item, which will be corrected under existing BG&E programs, and because we believe this screening procedure is not required to comply with existing regulations, we request you reconsider issuing the subject violation. l ITEM B l We have reviewed the circumstances that led to the apparent violation of Technical l Specifications 4.6.3.1, 4.6.6.1, 4.7.6.1, 4.7.7.1, and 4.9.12. This event was caused by an apparent misinterpretation of the Surveillance Requirements and a miscommunication with the contractor involved. Accordingly, the corrective action stated below will be implemented to ensure that similar violations will not recur in the future. The appropriate procedures will be revised to ensure that two separate samples are analyzed in accordance with the Surveillance Requirements. In addition, our contracts with outside laboratories will be altered to ensure that two distinct laboratory analyses are performed. These changes will be made by September 1,1986. Furthermore, we are considering submitting a license amendment request that changes the applicable Technical Specifications such that only one analysis is required of the charcoal sample. The procedures will then be revised again if a new Surveillance Requirement is issued. . .. . . - - }}