IR 05000317/1978036
| ML19261A740 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/07/1978 |
| From: | Clemons P, Crocker H, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19261A736 | List: |
| References | |
| 50-317-78-36, 50-318-78-21, NUDOCS 7902080089 | |
| Download: ML19261A740 (13) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION g
0FFICE OF INSPECTION AND ENFORCEMENT Region I 78-36 Report No. 78-21 50-317 Docket No. 50-318 DPR-53 License No. DPR-69 Priority
--
Category C
Licensee:
Baltimore Gas and Electric Comoany Gas and Electric Building Baltimore, Maryland 21203 Facility Nanie:
Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection at:
Lusby, Maryland Inspection conducted: Septem a 13-15, 1978 and October 10-13, 1978 Inspectors:
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[ R. Whit, Rad Qt1 a e signed Specialist 0 YbG
/2b/N P. Clemons, Radiation Specialist d'ats signed cate signed Approved by:
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. W. Crocker, Acting Chief, Radiation date' signed Support Section, FF & MS Branch Inspection Summary:
Inspection on September 13-15 and October 10-13,1978 (Combined Deport Nos.
50-317/78-36; 50-318/78-21 Areas Insoected:
Routine, unannounced inspection of the status of the Radiation Protection Program implemented for Unit 2 refueling outage.
Areas examined included Radiation Protection Procedures; Organization; Advanced Planning a.,d Preparation; Technical Specifications for Refueling; Training; Exposure Control; Posting and Control; and, Radioactive and Contaminated Material Control.
The inspection involved 65 inspector-hours on-site by two regional based NRC inspectors.
Resul ts_:
Of the eight areas inspected, four items of noncompliance were found in each of the following areas:
Infraction - (Unit 2) failure to perform surveys in ac-cordance with 10 CFR 20.201, Paragraph 6; Infraction - (Units 1 and 2) failure to control High Radiation Areas in accordance with Technical Specification 6.13, Paragraph 7; Deficiency - (Unit 2) failure to post a Radioactive Materials Area in accordance with 10 CFR 20.203, Paragraph 7; and, Deficiency - (Unit 2) failure to follow procedures in ac-cordance with Technical Specification 6.11, Paragraph 3.
Region I Form 12 (Rev. April 77)
790208Ogj
DETAILS 1.
Persons Contacted
- R. Douglass, Chief Engineer
- L. B. Russell, Nuclear Plant Engineer - Operations
- A. J. Kaupa, Radiation Safety and Chemistry Engineer
- E. Riemer, Plant Health Physicist J. Yoe, Training Specialist D. Thomas, Training Specialist J. Speciale, Foreman, Radiation Safety T. Goff, Shift Leader, Radiation Safety
- J. Lemons, Nuclear Plant Engineer - Maintenance
denotes those present at the exit interview conducted October 13, 1978.
The inspector also interviewed other individuals including plant (and contractor) health physics personnel and certain reactor and auxiliary operators.
2.
Organization Technical Specification 6.3, " Facility Staff Qualifications",
states:
"Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the Radiation Safety and Chemistry Engineer who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975."
ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, states the following:
"4.5.2 - Technicians Technicians in responsible positions shall have a minimum of two years working experience in their specialty..."
In order to support the Unit 2 refueling outage that cormenced on September 15, 1973, the licensee augmented the Radiation Safety Group (Health Physics) by contracting for the services of about 40 additional Health Physics Technicians.
On September 14, 1978, the inspector reviewed the qualifications of certain of these personnel that were intended to fill responsible positions.
Of 38 resumes reviewed, it was noted that only 17 of the individuals had qualifications in accord with ANSI N18.1-1971, Section 4. Upon notification, the licensee indicated that all of the individuals would be re-evaluated, and personnel changes would be made as necessary to assure that technicians in responsible positions met the qualifications of ANSI N18.1-1971.
On October 11, 1978, the ir.::pector again reviewed this area and noted that of the ten contractor-supplied technicians (randomly selected) who were in responsible positions, all met the specifications of ANSI N18.1-1971.
No items of noncompliance were identified in this area.
3.
Rad'iation Protection Procedures The following Radiation Protection Procedures were reviewed against the requirements stated in Technical Specification 6.8, " Procedures",
and Technical Specification 6.ll, " Radiation Protection Program":
RCP-3-201 Program 1 - Basic Radiological Control Indoctrination RCP-3-202 Program 2 - Employee Refresher Training RCP-3-301 Personnel Exposure Control Requirements for Wearing TLDs RCP-3-305 Source and Drift Checks for Self-Reading Dosimeters RCP-3-401 Radiological Surveys RCP-3-605 Respiratory Protection Program RCP-3-602 Radiation Work Permit (RWP)
RCP-3-603 Special Work Permit (SWP)
RCP-3-705 Special Maintenance Radiological Control Procedures Technical Specification 6.11, " Radiation Protection Program", states:
" Procedures for personnel radiation protection shall be pre-pared consistent with the requirements of 10 CFR Part 20 and shall be approveo, maintained and adhered to for all operations involving personnel radiation exposure."
On October 12, 1978, the inspector toured the Auxiliary Building and noted that an individual (TLD #285) was in the Unit 2 Charging Pump Room (an area that was posted and barricaded as a high radiation area; and was depicted as a high radiation area according to the licensee's radiological status board).
Upon inquiry, the inspector learned that the individual did not have a radiological survey meter which is required for entries into high radiation areas, in accordance with Technical Specification 6.13, "High Radiation Area".
It was also learned that the individual had entered the area under the control of Radiation Work Permit (RWP) R-6-78, issued in accordance with Procedure RCP-3-602, which requires adherence to the specifications in the RWP.
The inspector noted that RWP R-6-78 does not provide for access into high radiation areas.
The accompanying licensee representative directed the individual to leave the room and report to the Health rhysics Office.
At the inspector's request, the licensee surveyed the Unit 2 Charging Pump Room.
The survey results indicated that the room, in fact, was not a high radiation area; the highest dose rate measurable was s 40 mR/hr.
However, the inspector learned from discussion with the individual, that the person did not have any previous knowledge that the area was not as it was advertised to be, i.e. a high radiation area; and therefore, had no reason to believe that RWP R-6-78 provided for access to the area.
The inspector noted that the failure of the individual to observe the limitations of the RWP provided for his work; and to consequently enter an area for which the RWP was not intended constituted noncorrpliance with Technical Specification 6.11 (50-318/78-21-01 ).
The inspector noted that Procedure RCP-3.6G3, "Special Work Permit",
developed in accordance with Technical Specification 6.11, Radiation Protection Program, states in section 4.2.G, "Each person working on the job listed on the SWP must read the SWP and sign the SWP continuation sheet each shift prior to work on the operation covered by the SWP."
The inspector reviewed five SWPs issued for the outage, and their associated " continuation sheets" and noted that there was evidence that personnel were not adhering to this requirement in the majority of cases observed.
The inspector identified the following inforruation to exemplify this failure to adhere to procedures:
.
Number of Individuals Number of Individuals Who SWP No.
Who Performed Work Signed SWP Continuation Sheet 78-1040
18 78-1002
3 78-1030
14 On October 13, 1978, the inspector noted that the licensee's audit of the Radiation and Chemistry Department (Audit 18-32-78, dated October 12, 1978; performed between September 21, 1978 and October 6,1978) identified the same finding.
The Radiation Safety and Chemistry Engineer indicated that the licensee had acknowledged this finding and would identify and implement corrective action in a timely fashion, to assure adherence to the procedural requirements identified in RCP-3.603.
The inspector inoicated that this item would be reviewed in a subsequent inspection (50-318/78-21-06).
4.
Advanced Planning and Preparation The inspector noted that materials and supplies required to support the health physics related activities associated with the outage appeared sufficient.
It was also noted that the licensee implemented various training programs in advance of the outage to assure that personnel were familiar with the activities they were to perform.
Included in this training was Steam Generator Mock-Up operations, Radiological Training and Indoctrination for supplemental work force personnel, and preliminary procedure familiarization for the contractor-supplied health physics technicians.
No items of noncompliance were identified.
5.
Training An inspector participated in the licensee's general emnloyee training program given to employees, supplemental work force personnel and contractor-supplied personnel; and reviewed the program against the requirements of 10 CFR 19.12, " Instructions to workers".
No items of noncompliance were identifie.
Exposure Control The licensee's program was reviewed against the requirements of the following specifications:
" Exposure of individuals to radiation in restricted areas" 10 CFR 20.103
" Exposure of individuals to concentrations of radioactive materials in air in restricted areas" 10 CFR 20.104
" Exposure of minors" 10 CFR 20.201
" Surveys" 10 CFR 20.202
" Personnel monitoring" 10 CFR 20.401
" Records of surveys, radiation monitoring and disposal" 10 CFR 20.407
" Personnel exposure and monitoring reports" 10 CFR 20.408
" Reports of personnel exposure on termination of employment or work" 10 CFR 20.201, " Surveys", states in paragraph (b), each licensee shall make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part; and,10 CFR 20.103,
" Exposure of individuals to concentrations of radioactive materials in air in restricted areas", states in paragraph (a)(3), that for purposes of determining compliance with the requirements of this section, the licensee shall use suitable measurements of concentrations of radioactive m<.terials in air for detecting and evaluating airborne radioactivit, in restricted areas.
During a tour of the facility at 8:30 p.m., on September 13, 1978, the inspector observed work being performed in the Miscellaneous Waste honitor Tank Room (f!JMT Room) by four personnel under the control of Special Work Permit (SWP)78-899, " Install Strainer on Miscellaneous Waste Monitor Tank - 10' Auxiliary Building," which was issued on September 9,1978.
The inspector noted that initial survey data used to support the work associated with this permit was dated September 4,1978, and indicated the following:
Radiation:
General Area, 5 mrem /hr Hot Spots, 30 mrem /hr Loose Surface:
Alpha, < 100 dpm/100cm2
Beta / Gamma, 2500 dpm/cm Air Particulate:
1.5E-10 uCi/ml According to the SWP, radiological coverage by the Radiation Safety and Chemistry Department (Rad-Chem) was not required for this work, consequently there were no health physics technicians in the area supporting this evolution.
The inspector observed that the work being performed involved cut-ting out valve MSW-426 (a 10" diameter waste drain valve), weld prepping the cut ends, and reinstalling the valve by welding.
It was noted that the personnel were donned in full protective clothing including a full face respiratory device while performing work in accordance with the requirements of the SWP.
The inspector noted that the licensee takes credit for the use of respiratory protective equipment in accordance with 10 CFR 20.103.
After the initial cut on MSW-426 (made for removal of the valve)
the inspector requested one of the individuals to smear the surface of the cut in an effort to detect loose surface contamination.
A later evaluation of this sm r showed loose surface activity to be at least 200,000 dpm/100 cm The inspector brought this information to the attention of the health physics technician on duty that night, and indicated that such activity could result in airborne concentrations in excess of the values specified in 10 CFR 20.103; and would warrant the performance of surveys to determine the airborne concentration in the vicinity of the breathing zone of the workers, particularly when cutting, grinding or welding on the valve or associated piping.
The technician indicated that his management would have to be notified at home before performing such surveys.
Upon notification, the management representative (Foreman, Radiation Safety) agreed that such surveys were warranted, and consequently the technician performed an air survey in the area which indicated air activity to be 2.7E-10 uCi/ml. The inspector later learned that this survey was performed upon completion of the cutting and weld prepping operations in the MWMT Roo.
In further review of this area, the inspector noted that the licensee's procedure RCP-3-401, " Radiological Surveys" states the following in the listed sections:
3.3.2 During maintenance and refueling operations samples shall be obtained in areas where the evolution could cause significant increase in airborne particulate levels.
3.3.9 Upon opening of any system or component of any system that contains reactor coolant or other radioactive gaseous or liquid material, airborne iodine and parti-culate material shall be evaluated prior to commencement of work or entrance into any open system.
Periodic air samples should be taken while individuals are working on the system at intervals depending on the radiological hazard present.
The inspector verified that with the exception of the air sample he requested, no other measurements of airborne radioactivity were performed in direct support of the work permitted by SWP-78-899.
Upon inquiry as to why health physics coverage was not provided for the operations involving the removal of MSW-426, the inspector was told that the Radiation Safety and Chemistry Department was under the impression that the work was completed on September 7,1978, and consequently no information concerning the job was gi.en to the health physics technician providing coverage on the night of September 13, 1978.
The inspector noted that failure to perform surveys of the concentration of radioactive materials in air, particularly when conditions wera such that the potential for airborne activity existed, constituted noncompliance with 10 CFR 20.201; and indicated that use of respiratory protectiva equipment did not relieve the licensee from the requirement to provide surveys sufficient to demonstrate that the equipment was adequate to protect the individuals from exposure to the airborne concentrations of radioactivity (50-318/78-21-02).
7.
Posting and Control The inspector reviewed posting and control of radiologically controlled areas in accordance with the following requirements:
" Permissable levels of rodiation in un-restricted areas" 10 CFR 20.203
" Caution signs, labels, signals and controls" 10 CFR 20.207
" Storage and control of licensed materials in unrestricted areas" 10 CFR 19.11
" Posting of notices to workers" Technical Specification 6.13, "High Radiation Area".
Technical Specification 6.13, states in paragraph 6.13.l(a),
"In lieu of the " control device" or " alarm signal" required by paragraph 20.203(c)(2) of 10 CFR 20:
A High Radiation Area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as.a High Radiation Area and entrance theretc shall be controlled by issuance of a Special or Radiation Work Pm :t and any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicatas the radiation dose rate in the area."
During tours of the facility, the insoector noted the following in-stances of noncompliance with this requirement:
a.
On September 13, 1978, the inspector observed an Auxiliary Operator enter the barricaded and posted " Transient High Radiation Area" in the Valve Chase Passageway and enter the Unit 1 Valve Cha.n Room, a posted high radation area.
Upon inquiry, it was catermined that the individual did not have a " radiation monitoring device whie.h continuously indicates the radiation dose rate in the area."
The inspector requested the individual to make radiation measure-ments in the area with an instrument supplied by a licensee re-presentative, and noted that the radiation level in the area oc-cupied b3 the individual was 130 mrem /hr whole* body exposure.
The accompanying licensee representative directed the individual to leave the are The inspector noted that RWP-78-5 administratively controlled the work performed by this individual; and required an instru-ment be used in high radiation areas.
b.
On October 12, 1978, the inspector toured the -5' elevation of the Auxiliary Building to verify radiation levels in the Unit 1 and Unit 2 Charging Pump Rooms.
It was observed that the door to the Unit 1 Charging Pump Room, a posted high radiation area, was open.
The inspector noted that this door normally provided the barricading require-ment of Technical Specification 6.13.
An accompanying licensee representative made measurements of the radiation levels in the room and noted that the measurements to be s 600 mrem /hr at contact with certain components and piping; and s 100 mrem at about twenty-four inches from the piping and components, over an extended area (general area).
The inspector noted that there were no other personnel in the area providing surveillance to this unbarricaded high radiation area.
c.
On October 11, 1978, the inspector noted that the barricade and high r'.diation area postings were lying on the floor in the vicinity of the e7 trance foyer to the Let-Down Heat Exchanger Cubicle, Unit 2. Raciation surveys made by the inspector indicated that dose rates were s 300 mrem /hr at contact with certain components at the entrance to the cub :le, and 100 mrem /hr, general area.
The accompanying licensee representative re-established the posting and barricade in accordance with Technical Specification 6.13.
The inspector identified these items as examples of noncompliance with Technical Specification 6.13 (50-318/78-21-03; 50-317/78-36-01).
10 CFR 20.203(e)(1) states, "Each area or room in which licensed material is used or stored and which contains any radioactive material (ctner than natural uranium or thorium) in an amount exceeding 10 times the quantity of such material specified in Appendix C of this part shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
CAUTION RADI0 ACTIVE MATERIAL (S)
Additionally, the inspector noted that Procedure RCP-3-705. "Special Maintenance Radiological Control Procedures," states in Section 5.2.1, Paragraph 3, " Storage areas used to contain low level con-taminated items removed from the Controlled Areas are to be kept locked when not in use and only authorized personnel are permuted access into these areas."
During a tour of the facility on October 11, 1978, the inspector noted that radioactive material associated with the Unit 2 outage, was being stored in the Unit 2 Bulter Building.
The inspector made radiation measurements of the material and noted the dose rates to be as high as 3 mrem /hr at contact.
The material was labeled in accordance with 10 CFR 20.203(f), but the building, accesses to the building, and areas within the building were not conspicuously posted in accordance with 10 CFR 20.203(e)(1) with the exception of one access on the east side of the building which was appropriately posted.
Other accesses to the building (located on the north and west sides) were not posted.
The inspector also noted that contrary to RCP-3-705, the building, thcogh not in use, was not locked.
A licensee representative (Plant Health Physicist) verified that the activity of the material stored in the area was in excess of 10 times the quantity of such materials scecified in Appendix C of 10 CFR 20.
The inspector identified this item as noncompliance with 10 CFR 20.203(e)(1) (50-318/78-21-04).
8.
Radioactive and Contaminated Material Control The inspector observed the licensee's control of radioactive and contaminated material against the following requirements:
" Caution signs, labels, signals and control "
" Surveys" 10 CFR 20.207
" Storage and control of licensed materials ir; restricted areas"
.
Procedure RCP-3-501
" Packaging, labeling and movement of radioactive material within the controlled areas" Procedure RCP-3-501
" Storage of radioactive material" Upon inquiry from licensee representatives, as to what regulation concerning posting, labeling and control applied to radioactive material stored in trailers on-site awaiting shipment off-site, the inspector indicated that 10 CFR 20 applied to any licensed material in the licensee's possession; but that material that is immediately in the proccss of being shipped off-site is subject to the Department of Transportation (DOT) regulations contained in 49 CFR 170-189.
On Octobgr 10, 1978, licensee representatives re-evaluated several trailers containing radioactive material that were located on-stue awaiting shipment off-site, and determined that ona 3f the trailers though in accordance rith DOT regulations, had radiation levels of a 80 mrem /hr at contact with the side and s 5 mrem /hr over an extended area at 3 feet from tra trailer.
Upon this discovery, the licensee representative posted and barricaded the area as a radiation area in accordance with 10 CFR 20.103.
The Radiation Safety and Chemistry Engineer indicated to the in-spector that the applicable procedure would be reviewed and amended as necessary to assure that proper control is maintained in such cases.
The inspector indicated that this item would be reviewed in a subse-quent inspection (50-318/78-21-05).
9.
Technical Soecification for Refueling The following Technical Specifications were examined:
Technical Soecification Status 3.3.3.1 - Monitoring Instrumentation Monitors 2RI-5316 A, B, C and~ D (regarding Area Monitors - Contain-were verified to be operable.
Alarm ment Purge and Exhaust Isolation)
Set:
< 220 mr/hr.
3.9.2 - Instrumentation (regarding Channels C and D have been opera-source range neutron flux monitors)
tional since core alterations com-menced 9/27/78.
Surveillance Records reviewed from 9/27/78 to 10/9/7.
Technical Specification Status 3.9.1 - Boron Concentration (regarding Reactor Head was removed on 9/21/78.
shutdown concentration limit, i.e.,
From 9/21/78 to 10/10/78 Boron Con-
> 1720 ppm)
centration ranged between 1809 and
,
2171 ppm.
No items of noncompliance were identified.
10. Exit Interview The inspector met with the licensae representatives (denoted in para-graph 1) at the conclusion of tP: inspection on October 13, 1978.
The inspector summarized the scope and findings of the inspection as presented in this report.