IR 05000317/1978024
| ML19322A134 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/21/1978 |
| From: | Bores R, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19322A120 | List: |
| References | |
| 50-317-78-24, 50-318-78-18, NUDOCS 7901030020 | |
| Download: ML19322A134 (13) | |
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o U.S. NUCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT Region I 50-317/78-24 Report No. 50-318/78-18 50-317 Docket No. _50-318 DPR-53 C
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License No. DPR-69 Priority Category C
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Licensee:
Baltimore Gas and Electric Company Gas and Electric Building Charles Center Baltimore, Maryland 21203 Facility Name:
Calvert Cliffs Nuclear Power Plant - Units 1 and 2 (CC 1 & 2)
Inspection at:
Insp:ction conducted:
August 9 - September 1, 18-19, 1978 Inspectorc Yr f.
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R7 %. Bores, Radi6 tion SpecialTst d6te s Wned date signed date signed Approved by:
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/O 2d Tf J. f'. Sfohr, Chief, Environmental and date signed Special Projects Section
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Inspection Summary:
Inspection on August 29 - September 1, 18-19, 1978 (Combined Report Mos. 50-317/78-24 and 50-318/78-18)
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Areas Inspected:
Routine, unannounced inspection of emergency planning including:
licensee coordination with offsite support agencies; emergency facilities, equipment, instrumentation and supplies specified in the Emergency Plan and Implementing Procedures; training of emergency personnel; Emergency Plan Implementing Procedures; licensee records relating to emergency drills; the licensee's management controls in the area of emergency planning; and licensee action on noncompliance items and unresolved items noted in previous emergency planning and environmental monitoring inspections.
The inspection involved 37 direct-inspection hours by one NRC regionally based inspector.
Region I Form 12 730103OoM l
(Rev. April 77)
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Inspection Sumar[r:
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- esults: Of the 'seven areas inspected, no items of noncompliance were identified
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in two areas. Four items of noncompliance (Infraction - failure to establish adequate procedures - Details 4, 5.a, 5.b and 8; Infraction - failure to imple-ment procedures / training - Details 6; Deficiency - failure to implement pro-
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cedures/ records and reports'- Details 7; and, Deficiency - failure to maintain condenser AT within~ Environmental Technical Specification limits - Details 10) were identified in five areas.
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DETAILS 1.
Individuals Contacted a.
Principal Licensee Employees a,b-R. M. Douglass, Chief Engineer a,b-A. J. Kaupa, Radiation Safety and Chemistry Engineer b-L. B. Russell, Nuclear Plant Engineer - Operations a,b-J. R. Lemons, Nuclear Plant Engineer - Maintenance a-J. T. Carroll, Performance Engineer - Operations a,b-R. E. Denton, Supervisor - Technical Support a-S. E. Jones, Performance Engineer - Training a-T. L. Sydnor, Performance Engineer - SEP Coordinator a-E. T. Reimer, Plant Health Physicist a-M. E. Bowman, Supervisor - QA Audit Unit b-W. S. Gibson, Supervisor - Operations, QA J. Speciale, Foreman - Radiation Safety and Chemistry b-P. T. Crinigan, Engineer - Radiation Safety and Chemistry E. R. Bauer, Foreman - Maintenance L. S. Hinkle, Foreman - I&C, Unit 1 J. R. Hill, Shift Supervisor L. P. Strayer, Senior Control Operator S. Koranek, Rad-Chem Technician R. Parrott, Senior Security Guard J. Flinn, Security Guard The inspector also interviewed several other licensee employees of the Radiation Safety and Chemistry Department.
a-denotes those present at the exit interview on September 1, 1978.
b-denotes th'ose present at the exit interview on September 19, 1978.
b.
Other Personnel J. Jacobs, Administrator - Calvert County Hospital I. Gibson, Supervisor of Communications - Maryland State Police and Calvert County Volunteer Fire & Rescue Service T. Murn, Assistant Operations Officer - Maryland Civil Defense and Disaster Preparedness Agency Captain C. Ralon, Rescue Officer - Solomon's Volunteer Rescue Squad and Fire Department
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2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (318/76-29-01): Audibility of emergency alarms.
The inspector determined through discussions with the licensee and review of documentation, that modificat. as of the plant page system had been completed in May, 1977.
The modifica-tions enable the emergency alarms to bypass the speaker volume controls such that the alarms are sounded at maximum volume.
The inspector had no further questions in this area.
(Closed) Infraction (317/77-20-01; 318/77-19-01):
Inadequate maintenance of emergency equipment.
The inspector determined through review of documentation, discussions with the licensee and independ-ent inventory of selected emergency kits and equipment that the licensee's corrective actions were as stated in his letter of September 19, 1977 to NRC:I.
The inspector had no further ques-tions regarding this item.
(See Detail 5.b, however, for a re-lated item).
(Closed) Infraction (317/77-20-02; 318/77-19-02):
Failure to implement provisions with local fire departments.
The inspector detennined through discussions with the licensee and local fire department personnel and through the review of the 1977 emergency drill reports, that the local fire department participated in a drill at CC in 1977.
The inspector further noted that the drill procedure had been modified to assure fire department participa-tion in drills at least every second year.
The licensee stated that initially one of the local "first-alarm" fire departments would be invited each year until all had participated in a drill.
The inspector had no further questions in this area.
(Closed) Unresolved Item (317/77-20-03; 318/77-19-03):
Distri-bution of emergency plan and implementing procedures.
The inspector reviewed the distribution list of the emergency plan and imple-menting procedures and discussed this item with the licensee.
The inspector had no further questions regarding this item.
(See Detail 8, however, for a related item).
(Closed) Deficiency (317/77-25-05; 318/77-24-06):
Delta T in ex-cess of limits.
The inspector reviewed the licensee's corrective and preventive actions as documented in letters to the NRC.:I on February 3,1978 and March 20, 1978, held discussions with the licensee and reviewed the operating records since November,1977
related to this item.
The inspector had no further questions in this area at this time.
(See Detail 10).
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3.
Coordination with Offsite Agencies The inspector reviewed records, procedures and written agreements relating to the licensee's coordination of emergency planning with agencies listed in the Emergency Plan and Implementing Procedures.
The inspector discussed this subject with licensee representatives and persons of 5 offsite agencies, a.
Calvert County Hospital; b.
Maryland State Police; c.
Calvert County Volunteer Fire and Rescue Service; d.
Maryland Civil Defense and Disaster Preparedness Agency; and, e.
Solomon's Volunteer Rescue Squad and Fire Department.
These discussions verified that the existing agreements between the licensee and these agencies remain in effect, and that the licensee's contact and coordination were adequate for these agencies to maintain an effective response capability.
No items of noncompliance were identified.
4.
Facilities and Equipment The inspector examined facilities, equipment and instrumentation to verify that items specified in the licensee's Emergency Plan and Implementing Procedures were available for use and maintained in an operable state. The inspection included examination of:
a selection of three items of emergency communications equipment;
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radioactive release monitoring instruments - area and process
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monitors, and meteorological instruments; medical treatment /decon-tamination facilities, both onsite and at the local hospital; four emergency equipment kits; and the primary and alternate emer-gency control centers and associated supplies and equipment.
The inspector noted that the licensee's instrumentation for emergency air sampling and analysis consisted of low-flow (approxi-mately 101pm),12 volt DC-powered, air samplers; particulate filters and charcoal cartridges; and G-M detector / rate-meter j
measuring instruments.
The inspector determined, through review i
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of the air sampling procedure, SEPIP A Section V.A; evaluation of available instrumentation with a calibration source; and discussions with the licensee, that the above combination of procedures and equipment was inadequate for the licensee to evaluate air iodine concentration of 5x10-8 microcuries/cc or less.
5x10-8 microcuries
/cc is an action level specified in Section V of the Site Bnergency Plan (SEP) and in SEPIP A of the Site Emergency Plan Implementing Procedures.
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The inspector also noted that, as a result of changes made to the power supplies of the emergency air samplers in the Emergency Control Center (ECC) since the last drill (November,1977), these air samplers could no longer be utilized within the ECC to deter-mine whether the ECC remains tenable during the course of an emergency.
The inspector stated that the inadequacy of Procedure SEPIP A Section V.A with regard to implementing the SEP was in noncompliance with Technical Specification (TS) 6.8.1, which requires that writ-ten procedures be established and followed to implement the Emer-gency Plan (317/ 78-24-01; 318/78-18-01).
(See Details Sa, 5b, and 6 for related items).
Prior to the completion of the inspection on September 19, 1978, the inspector verified that:
a.
An AC-power air sampler was:
(a) provided for use in the ECC; (b) provided with particulate and charcoal cartridge sampling media; and (c) calibrated for flow rate and airborne iodine collection efficiencies;
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b.
Temporary procedure changes and instrument modifications had been made, such that the sampling times and air volumes col-lected could enable the licensee to detect an airborne I-131 concentration of 5x10-8 microcuries/cc; and, l
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The licensee was actively pursuing more permanent improvements to the airborne radioactivity evaluations for emergencies; including sampler capacities, sampling media and analytical instruments. The licensee stated that the modifications to the airborne radioactivity measurements equipment and pro-cedures would be documented in a letter to the NRC by the end l
of September 1978, along with connitment dates by which these actions / modifications would be accomplished.
This letter, dated September 26, 1978, was received and reviewed at the NRC:I office.
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In view of the imediate and interim actions taken by the licensee and commitments for overall upgrading of the above capabilities, the inspector stated that he had no further questions regarding the licensee's ability to implement this portion of the Site Emergency Plan in the interim.
The inspector stated that with re-spect to the overall upgrading of the emergency airborne radio-activity monitoring capabilities, this item would be considered unresolved until the planned upgrading in this area is completed (317/78-24-02; 318/78-18-02).
The inspector noted that in addition to action levels based on concentration of airborne radioactivity, the SEP has action levels based on direct gamma radiation levels.
The licensee stated that the majority of the postulated accident sequences analyzed in the CC FSAR indicated that the gamma radiation action levels would have been reached prior to that of the airborne radioactivity. The inspector noted that the licensee's capability to measure the gamma radiation levels was adequate to implement that portion of the SEP.
5.
Calibration, Inventory, and Operational Checks of Emergency Equipment The inspector reviewed the adequacy of procedures and schedules
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established by the licensee for calibrating, maintaining and in-specting the emergency response equipment required by the SEP, SEPIPs and/or Technical Specifications.
The inspector reviewed a sampling of calibration, inventory, and operational check records
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covering the period from the First Quarter 1977 through Second Quarter, 1978 for the emergency response equipment.
Records reviewed covered survey instrument calibration, emergency equip-ment inventories / checks, communication equipment checks, area and process monitor calibrations, and medical treatment / decontamination supplies and equipment.
The inspector noted the following exceptions to the licensee's requirements:
a.
SEPIP A indicates that the counting efficiency of emergency counting instrumentation located in the emergency kits is posted on each instrument.
The inspector found that the detector counting efficiencies were not posted, as indicated.
Further, the inspector determined through discussions with i
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several licensee representatives having emergency radiological monitoring responsibilities that there was uncertainty re-garding the efficiency to be used.
Individual responses varied from 5% to 20% for efficiencies and the inspector noted a graph provided in the kits which assumed a 10% efficiency.
(See Detail 6)
The inspector reviewed the instrument calibration records and procedures and noted that the rate-meters employed for assessing airborne activity were electronically calibrated and were checked for detector response using an alpha source and a gamma field. The inspector determined, however, that no calibrations had been performed specifically for using the rate-meter /G-M detector assembly for measuring radiciodine in a charcoal cartridge or analyzing particulate filters-their intended use in the emergency kits.
The inspector further noted that the calibration procedure employed was deficient, in that, it did not provide for calibration of these instru-ments for analyzing charcoal cartridges or particulate filters.
The inspector stated that the failure to have such calibration procedures was in noncompliance with Technical Specification (TS) 6.8.1 (317/78-24-03; 318/78-18-03).
Prior to the completion of this inspection on September 19, 1978, the inspector verified that the licensee had calibrated the rate-meter /G-M detectors in the Emergency Kits for I-131 on/in charcoal cartridges and had posted the measured efficiency (approximately 0.3%) on each detector. The licensee had not
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yet completed the calibration for counting particulate filters for radioactivity.
b.
The inspector determined through his independent inventory of selected emergency equipment and kits on August 30, 1978, that the Decontamination Kits in the Controlled Area Medical Treatment Room and at the Farm Demonstration Building contained saline solutions which had posted expiration dates of November 1, 1977 and December 1,1977.
In addition, a number of bottles
.of intravenous solutions (glucose and plasmamate) all of which had expiration dates between June 1976 and December 1977, were stored in the Controlled Area Medical Treatment Room.
The inspector determined through discussions with the licensee and
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review of available documents, that the contents of the De-contamination Kits were not routinely inventoried by CC.
The inventory procedure, SEPIP B, only requires verification that the Decontamination Kits were available.
The inspector also determined that the medical supplies in the Controlled Area Medical Treatment Room were not routinely inventoried.
The inspector stated that Section VII.2.C and Appendix B of the SEP require twice a year inventories and replenishment of medical treatment room supplies.
The inspector stated that this failure to perform the above inventories and the failure to have an inventory procedure for emergency treatment supplies and equipment was in noncompliance with TS 6.8.1, which requires that procedures be established and implemented for activities related to the Site Emergency Plan (317/78-24-04; 318/78-18-04).
6.
Training The inspector reviewed training related documentation and proce-dures and interviewed six persons assigned to the licensee's emer-gency organization to verify that training required by the Emergency Plan and Implementing Procedures had been conducted.
Training conducted since January 1977 included sessions for the Site Emergency Directors, Emergency Coordinators, Emergency Radiation Teams, Fire Brigade, First Aid and Decontamination Team, the Emergency Security Team and offsite support organizations, as well as, for general employees and contractor employees.
The inspector determined through the review of the available records and discussions with licensee personnel, that one or more individuals assigned emergency responsibilities by the SEP/SEPIP in each of the following areas Site Emergency Director, Emergency Coordinator, Emergency Radiation Team, Fire Brigade, Emergency First Aid and Decontamination Team, and Emergency Security Team - had not received training / retraining in 1977 or 1978. The inspector stated that the failure to train /re-train these individuals in their assigned emergency responsibilities was in noncompliance with Section VIII of the SEP and with Proce-dure CCI-611C (317/78-24-05; 318/78-18-05).
The inspector noted that as of September 1,1978, Site Emergency Director Training had been given to one additional individual assigned by the SEP, such that the Site Fmergency Director training was current for at least one i ni,..:al on each operating shift at CC.
In addition, as of c.ner 7,1978, the licensee had verified from the SEP training records that individuals on each shift, who were assigned emergency responsibilities, had received the required annual training.
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i With regard to the training of individuals in performing the emer-gency airborne radioactivity monitoring, the inspector determined through discussions with licensee employees assigned to Emergency Radiation Teams, that the conducted training had not included the actual analyses of air. samples, nor had previously ccnducted emergency drills included these analyses. As a result, Emergency
Radiation Team members had expressed uncertainty in following the
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monitoring procedure, SEPIP A Section V.A (See also Cetail 5.a).
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Prior to the completion of the' inspection on September 19, 1978, the inspector verified that training had been conducted for the Rad-Chem personnel on the Emergency Radiation Team and that this training had included the modifications to the sampling and analy-l tical procedures, sampling times, counting efficiencies and analy-tical techniaues. The licensee stated that the Radiation Moni-toring Person'nel (Operation Dept.) assigned to the Emergency Radiation Team would receive specific training in the above areas when these individuals reported to their next work shift.
Procedures CCI-405A and CCI-611C require, in part, that an annual review of the SEF training conducted be performed and documented in i
a report to the Chief Engineer. The inspector determined through
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the review of available records and discussions with the licensee that the above review had not been performed nor a report submitted for the 1977 SEP training. The inspector stated that this failure to follow procedures resulted in an item of noncompliance with TS 6.8.1 which requires that procedures be followed (317/78-24-06; 318/78-18-06). The inspector noted that the required review and report were to be used by the licensee to assure that the indivi-duals assigned SEP responsibilities were properly trained and in
updating the complement of CC personnel assigned specific emergency responsibilities.
7.
Emergency Drills The inspector reviewed records of two medical and one site emer-gency drills conducted since the previous emergency planning in-spection.
The medical drills involved coordination with and parti-cipation by the Calvert County Volunteer Fire and Rescue Service and the Calvert County. Hospital.
The site emergency drill had involved the participation by the Solomon's Volunteer Rescue Squad and Fire Department.
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The inspector determined that for each emergency drill, the licensee used qualified personnel to evaluate the organization's response and conducted a drill critique, during which discussion highlighted improvement possibilities.
The inspector reviewed the licensee's actions to resolve the identi-fled drill items needing followup.
The inspector determined that action on several of the items from the November 1977 site emergency drill had not yet been initiated (e.g. status board modification and training related items) and that the training related to the 1977 medical emergency drill items had been conducted with only three of the approximately 20 first aid team members.
The inspector noted that procedures CCI-611C requires that within two months of the conduct of a drill, a report of action taken, based on drill comments / recommendations, be submitted to the CC Chief Engineer.
The inspector determined that no reports of action taken were submitted as required for the 1977 medical nor site emergency drills. The inspector stated that this was in noncompliance with the TS 6.8.1 which requires that procedures be followed (317/78-24-07; 318/78-18-07).
The inspector further noted that Procedure CCI-611C also requires that records be kept of individuals and outside agencies partici-pating in emergency drills.
The inspector determined through dis-cussions with the licensee and review of the available records, that individual drill participation records were not kept for the 1977 emergency drills. The inspector stated that this was in non-compliance with TS 6.8.1, which requires that procedures be followed (317/78-24-08;318/78-18-08).
8.
Site Emergency Plan and Emergency Plan Implementing Procedures The inspector reviewed and evaluated changes to the SEP and Site Emergency Plan Implementing Procedures and determined that with the exception of the procedure for emergency air monitoring, SEPIP A,Section V.A, the revised procedures provided the same or higher degree of preparedness than previous ones and that changes had been reviewed and approved as required. With regard to SEPIP A,Section V.A, detail was lacking to assure sampling and analyes were performed in a consistent manner. The licensee stated that this procedure would be rewritten to assure that, when combined with the required training / retraining, consistent techniques are used and results achieved.
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4 Section V.E.1 of the Site Emergency Plan requires that "The imple-menting procedures will contain adequate measures to ensure that -
the numbers and locations of.all persons on the site are known at all times and that they will be quickly warned and evacuated when necessary," and that "Such provisions will include persons engaged in farming....".
The inspector determined through review of the
implementing procedures and discussions with the licensee that provisions had not been made for accounting for persons engaged in farming at the CC site nor for notifying and evacuating them, as necessary. The inspector stated that the failure to have such procedures was in noncompliance with Section 6.8.1 of the TS (317/78-25-09; 318/78-18-09).
The inspector also noted that Sections VIII b(2) and IX of the SEP require that complete copies of the SEP be distributed to all offsite support groups.
The inspector determined through the re-view of the SEP distribution list and discussions with licensee and I
offsite agency personnel, that outside support groups, such as, the hospital, fire departments and rescue squads, did not have copies
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of the CC SEP. The ins with the requirements (pector stated that this was in noncompliance 317/78-25-10; 318/78-18-10).
9.
Management Control - Emergency Planning a.
Established / Documented Program The inspector verified, through the review of procedures and applicable technical specifications and through discussions with responsible licensee' personnel, that a clearly defined program of management control over emergency planning acti-vities had been established. This program consists of:
the delineation of planning responsibilities and authorities; j
provisions for periodic reviews, audits and updates of Emer-gency Plan implementation; and delineation of responsibility
for overall conduct of reviews, audits and updates.
b.
Reviews and Audits The inspector reviewed reports of two Quality Assurance audits covering the Emergency Plan and Implementing Procedures. The inspector noted-that the audit reports noted several items re-quiring further action.
Further review indicated that all items had been evaluated and resolution was completed.
No items of noncompliance were identified.
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10. C;ndenser AT The inspector reviewed the effectiveness of the licensee's correc-tive and preventive actions, as described in the licensee's letters of February 3 and March 20, 1978, relative to maintaining the con-denser cooling (water AT within the specified Env1ronmental Technical Specification ETS) limits of 10*F.
The inspector determined, through discussions with the licensee and review of selected records, that with two exceptions, the above limits had not been exceeded.
The inspector reviewed of the two exceptions, reported by the licensee as:
Report Letter date Event Date AT LER 317/78-35/4T 7/20/78 7/14/78 10.1*F LER 317/78-36/4T 7/27/78 7/23/78 10.3*F In the first instance, the licensee determined that the rise in AT resulted from excessive condenser Guling due to a gap between the bottom of the intake screens and the intake structure floor.
Corrective action to reduce the above gap was taken in a timely fashion,
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In the second instance, some changes were experienced in the delay time between the inlet temperature sensors and the discharge tempera-ture sensors, such that a change in the inlet temperature was not accounted for by the computer in the proper time sequence to main-tain AT within the limits. The licensee had since (1) recalibrated the temperature senso's and (2) as of August 20, 1978 remeasured the delay sequence. As of September 15, 1978, the licensee anti-cipated that the modified computer program would be in operation.
The licensee stated that the delay between August 20 and September 15, 1978 was due, in part, to the desireability of determining any affects due to instrument calibrations alone.
The inspector stated that while. the two events reported by LERs above were items of noncomplians e with ETS 2.1.1 for exceeding the AT limit of 10*F, the inspector iad no further questions at this time regarding the above LERs no with the licensee's corrective and preventive action.
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11.
Unresolved Items Unresolved items are matters about which more information is re-quired in order to ascertain whether they are acceptable items, items of noncompliance or deviations.
An unresuived item disclosed during this inspection is described in Detail 4.
12.
Exit interview
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The inspector met with licensee representatives denoted in Detail 1 on September 1 end at the conclusion of the inspection on September 19, 1978. On October 24, 1978, the inspector contacted Messrs.
Douglass and Russell by telephone. During these meetings / contacts, the inspector sunnarized the purpose, scope and findings of this inspection.
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