IR 05000317/1979008
| ML19209C548 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/06/1979 |
| From: | Crocker H, Nimitz R, Thonus L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19209C531 | List: |
| References | |
| 50-317-79-08, 50-317-79-8, 50-318-79-07, 50-318-79-7, NUDOCS 7910160117 | |
| Download: ML19209C548 (13) | |
Text
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT ' Region I - Report No. 50-317/79-08; 50-318/79-07 Docket No. 50-317; 50-318 DPR-53 License No. DPR-69 Priority Category C, C -- - Licensee: Baltimore Gas and Electric Company P. O. Box 1475 Baltimore, Maryland Facility Name: Calvert Cliffs Nuclear Power ?lant, Units 1 and 2 Inspection at: Lusby, Maryland Inspection conducted: May 21-25, 1979 [[ /cf Inspectors: / L. A. Thonus, Radiation Specialist date signed - M f!/ /7 7 R f itz, Radiation Specialist date'sig6ed - - - - date signed Approved by: I, M f/gg9 c, H. W. Crocker, Acting Chie'f / date signed Radiation Suport Section FF&MS Branch Inspection Summary: Inspection on May 21-25, 1979 (Combined Report Nos. 50-317/79-08; 50-318/79-07) Areas Inspected: Routine, unannounced inspection by regional based inspectors of the radiation protection program during refui'ing; including radiation protection procedures; training; advanced plannin material control; surveys;g and preparac1on; exposure control; radioactive and contaminated posting and control; and followup on IE Bulletins and previous enforcement action.
Upon arrival at 5:30 P.M. on May 21, 1979, areas where work was being conducted were examined to review radiation safety control procedures and practices. The inspection involved 70 inspector-hours on site by two NRC region based inspectors.
Results: Of the eight areas inspected one item of noncompliance (deficiency -failure to post radioactive materials areas, units 1 and 2) was found in one area.
1147 205 Region I Form 12 7910160 (Rev. April 77)
DETAILS 1.
Persons Contacted
- L. B. Russel, Chief Engineer
- A. J. Kaupa, Radiation Safety and Chemistry Engineer
- E. T. Reimer, Plant Health Physicist
- J. R. Speciale, Radiation Safety and Chemistry Foreman
- J. T. Carlson, Radiation Safety and Chemistry Foreman
- M. E. Bowman, Supervisor, Operations QA Audit Unit J. Yoe, Training Specialist D. Thomas, Training Specialist D. Zyriek, Shift Supervisor, Operations C. Woodie, Asst. General Superintendent Security Services
- Denotes those present at the exit interview conducted May 25, 1979.
The inspector also interviewed other licensee employees including members of the Health Physics staff (station and contractor) and certain reactor operations and maintenance personnel.
2.
Licensee Action on Previous Inspection Findings a.
(Closed) Unresolved Item (50-317/76-22-01): Review pro-cedural change for gross alpha determination of reactor coolant.
The inspector reviewed Change Report 76-81 to Procedure RCP-2-410.
The procedural change, effective December 23, 1976, incorporated a threshold change for the alpha instrumentation to correct for overstated alpha activity.
Discussions with cognizant licensee representatives indicated that the threshold change did correct the overstated alpha activity.
b.
(Withdrawn) Noncompliance (50-317/78-22-01; 50-318/78-16-01): Failure to include qualification cards and check-off sheets in training records of Rad-Chem personnel.
The inspector reviewed the recovered and refiled personnel training data and reviewed the revised training instruction CCI-607B as addressed in licensee response to combined inspector numbers bv-317/78-22;50-318/78-16(Details, Paragraph 9.). c.
(Closed) Unresolved Item (50-317/78-22-05; 50-318/78-16-05) Administrative control of Neutron Exposure.
The inspector reviewed Change Report 78-38, effective September 6, 1978.
, 1147 206
-3-The change report specifically incorporates into procedure RCP-3-301, "Personncl Exposure Control", the requirements for Chief Engineer and Radiation Safety and Chemistry Engineer approval for neutron exposures in excess of 300 mrem in a current calendar quarter.
3.
Licensee Action on IE Bulletins (Closed) IE Bulletin 78-08 (Radiation Levels from Fuel Element Transfer Tubes): The inspector interviewed licensee representatives to verify follow-up actions as addressed in the licensee's bulletin response dated July 21, 1978.
Areas reviewed included: Licensee surveys of the fuel transfer tube during fuel movement -- Licensee shield design review -- High radiation areas identified by above -- Shielding modifications -- Access control and area posting -- The inspector had no further questions at this time.
4.
Radiation Protection Procedures a.
Procedure Preparation / Revision The inspector reviewed the following procedures to verify preparation and/or revision in accordance with the re-quirements of Technical Specification 6.8, " Procedures" and Rad-Chem Procedure RCP-1-101, " Methods for Revising and Charging Rad-Chem Procedures."
. RCP-3-602, " Radiation Safety Procedure Radiation Wcrk Permit", -- Rev. 3 dated March 28, 1979 RCP-3-603, "Special Work Permit" Rev. 9 dated January 10, -- 1979 RCP-3-306, " Determination of Neutron Exposure", Rev. 2 dated -- July 31, 1978 1147 207
-4-Radiation Chemistry Procedure RCP-1-101 requires in Section 2.2, " Changes to Rad-Chem Procedures", that copies of changes be placed into each working set of RCPs and the change report log.
Additionally, Calvert Cliffs I1struction, CCI-404A, "Calvert Cliffs Radiation Safety and Chemistry Procedure Format", requires in paragraph VII, " Issue and Distribution", that changes will be entered only in the RCP copies listed in Attachment 2 to CCI-404A as operational copies.
Attachment 2 thereto identifies the RCP copy in the Rad-Chem Area, as an operational copy.
This copy per dfscussion with licensee representatives and Rad-Chem technicians is normally utilized by the licensee Rad-Chem technicians for reference.
The inspector reviewed RCP Change Report 78-38 to Procedure RCP-3-301, " Personnel Exposure Control", Rev. 9 dated March 15, 1978, with respect to the above requirements.
Change Report 78-38, effective September 6,1978 set an administrative limit of 300 mrem neutron exposure in a current calendar quarter.
During distribution review, the inspector noted that the Rad-Chem Area Operations Copy did not contain the above change report.
Inspector review indicated that a copy of the change report had been distributed to the other appropriate operating copies.
The inspector questioned licensee representatives as to how they insured that the appropriate Rad-Chem technicians had been made aware of the above change.
The inspector was presented a " Rad-Chem Sign Off Sheet" for RCP Change Report 78-38, which contained the technician's signatures indicating they had read the change.
The inspector noted that 5 additional technicians had been hireo after issuance of the change who had not signed the original sign-off sheet thereby indicating they had read the neutron quarterly dose limit change report.
The inspector expressed concern to licensee representatives regarding the above.
Particularly since the change report is to remain in effect until "the availability of a neutron dosimetry system at the facility".
. i 1147 208
5-Dist > ions with licensee representatives indicated a new " Rad-tnem Sign-Off Sheet" would be circulated to the affected technicians to insure reading of the change report.
The inspector indicated that the methods for revising and changing procedures would be reviewud at a subsequent inspection, particularly with respect to the distribution of same(50-317/79-08-01;50-318/79-07-01).
b.
Procedure Adherence T.S. 6.11, " Radiation Protection Program", requires that procedures for personnel radiation protection shall be pre-pared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Procedure RCP-3-101, " General Safety", Rev. O dated October 3, 1972 states in paragraph 18, " Wear protective clothing and respiratory devices commensurate with hazards of the job to be performed, but never less than minimum prescribed protection as listed on the status board, RWP or SWP."
The inspector made tours of the controlled areas upon initial arrival on May 25, 1979 and at other times during the inspection. The inspector noted that personnel appeared to be adhering to the requirements of Procedure RCP-3-101.
During review of procedures in the Rad-Chem Area on May 24, 1979, the inspector became aware of an individual expressing concerns to a licensee Rad-Chem technician.
The individual's concerns appeared directea toward licensee contractor health ;,hysics technician performance on the 10 foot elevation of the Unit 1 containment.
I.7c. tor discussions with the coanizant licensee Rad-Chem technician indicated the following (1) On May ;!3,1979, licensee contractor technician A made an entry into the 11 Reactor Coolant Pump Bay under special work permit (SWP) No. 79-375B to obtain an air sample of the area without the use of respiratory protective equipment.
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-6-Inspector review of SWP-375B indicated in Section IV, Respiratory Protection Device Required, that respirators were to be worn "as required by Rad-Chem".
The inspector noted through discussions with the cognizant licensee Radiation-Chemistry technician that contractor health physics technicians had specifically been directed by Rad-Chem to wear respiratory protection equipment in the Reactor Coolant Pump bays.
(2) On May 23, 1979, licensee contractor technician B, con-trolling 10 foot containment access point, granted access to a licensee inservice inspector to enter the 11 Reactor Coolant Pump Bay under SWP No. 79-379A to perform inspections of various pipe hangers in the area without use of the required respiratory protection equipment.
Inspector review of SWP-379A indicated in Section IV; Respiratory Protective Device Required, that MSA respirators with particulate filters were to be worn in Pressurizer House, Pump Bays and as required by Rad-Chem.
Through further discussions with the cognizant licensee Rad-Chem technician, the inspector noted that the inservice inspector denoted above had entered the Reactor Coolant Pump Bay area without the use of respiratory protective equipment as required by their respective SWPs per recommendation of licensee contractor health physics technician B (above).
A licensee representative stated that the licensee con-tractor health physics technician A had apparently suspended the requirements of the use of respiratory protection in the above area, based on results of air-borne radioactivity determinations performed at some earlier time without the review and concurrence of li-censee health physics representatives.
The inspector noted that Procedure RCP-3-605, Respiratory Protection, R.v. 2 dated April 1, 1976 states in paragraph 3.1 that " Respiratory equipment shall be worn anytime that..... beta-gamma contamination exceeds 150,000 dpm/100 cm2 regardless of airborne radioactivity determination".
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. --7-Inspector review of SWP-379A indicated in Section II, Radiation and contamination control, that beta-gapa contamination ranged from 50 - 200,000 dpm/100 cm. The licensee had identified this failure to follow procedures and initiated corrective actions. The inspector reviewed the licensee's corrective actions taken and noted that the involved contractor technicians were removed from the 10 foot containment control point and placed in an area of lesser responsibility.
The licensee was evaluating further corrective action at the time of the inspection.
The inspector discussed the significance of the above entries with licensee health physics representatives specifically with respect to contractor technicians suspending the requirements of Special Radiation Work Permits without licensee Radiation Chemistry review and concurrence.
The inspector indicated that the above item would be reviewed at subsequent inspection (50-317/ 79-08-02; 50-318/79-07-02).
5.
_ Exposure Control a.
Personnel Monitoring The inspector reviewed the exposure records of 20 individuals who received exposure in the period April 1, 1979 through May 22, 1979. The inspector reviewed the exposure records against the following criteria: 10 CFR 20.101, " Exposure of individuals to radiation in restricted areas"; 10 CFR 20.102, " Determination of Accumulated dose"; and 10 CFR 20.401, " Records of Surveys, radiation monitoring, and disposal."
No items of noncompliance were identified in this area.
b.
Respiratory Protection The inspector established through discussions with licensee representatives that the licensee makes allowance for the use of respiratory protective equipment in limiting the inhalation of airborne radioactive material.
1147 211
. -8- . The inspector reviewed the licensee's respiratory protection program against the following: 10 CFR 20.103, " Exposure of individuals to radiation in -- restricted areas" Regulatory Guide 8.15, Acceptable Programs for Respiratory -- Protection NUREG-0041, Manual of Respiratory Protection Against Airborne -- Radioactive Materials Procedure RCP-605, " Respiratory Protection" -- The inspector reviewed respirator issuance, fitting (quan-titative and qualitative), collection, decontamination, cleaning and disinfection, inspection, repair and respirator storage.
The inspector review indicated the licensee utilizes a wet solution to decontaminate and disinfect reusable respiratory protective equipr.ient.
Further inspector review indicated that after drying and subsequent reassembly, a technician dons the respiratory equipment, performs a negative pressure check and subsequently bags the equipment for reissuance as determined by tne results of the negative pressure test.
The inspector expressed concern to licensee health physics representatives regarding the practice of reissuing respirators that have been donned by individuals other than those who will finally use the equipment in performing their work function.
Discussions with licensee health physics representatives re-garding the above indicated that a second disinfection will be performed prior to bagging the respiratory protection equipment for reissuance.
Licensee health physics represen-tatives indicated the second disinfection would be performed in solutions separate from ".;ose used for the initial dis-infection.
The inspector ir.dicated this item will be reviewed at a subsequent inspection (50-317/79-08-03; 50-318/79-07-03).
. 1147 212
g - No items of noncompliance were identified in this area.
c.
Whole Body Counting The inspector selected twenty individuals from various Special Work Permits (SWP) requiring the use of respiratory protective equipment.
The individual's records were reviewed against the following: 10 CFR 20.103, " Exposure of individuals to concentration of radioactive material in air in restricted areas", Technical Specification 6.8, " Procedures", and Procedure RCP-3-309, " Bioassays".
No items of noncompliance were identified in this area.
6.
Radioactive and Contaminated Material Control The inspector toured the controlled areas and noted that radioactive and contaminated material control appeared satisfactory in relation to control and housekeeping requirements.
Radioactive material appeared to be adequately identified and labelled in accordance with 10 CFR 20.203 (f), " containers", Rad-Chem Procedure RCP-3-501, " Origin and Disposal of Radioactive Material", and Rad-Chem Procedure RCP-3-502, " Low Level Solid Radioactive Waste Control".
During tours of the Unit I containment elevation, the inspector noted highly radioactive material to be controlled in accordance with Procedure RCP-3-611, " Handling Highly Radioactive Material", Rev. O dated March 27, 1973 and Procedure RCP-3-607, " Total Con-tainment Requirements", Rev. 2 dated July 13, 1976.
No items of noncompliance were identified in this area.
7.
Posting and Area Control During several tours of the licensee's radiation control area and radioactive material stcrage areas the inspectors examined several radiation areas, high radiation areas, airborne radioactivity areas and radioactive materials for compliance with posting and control requirements of 10 CFR 20.203 and licensee procedure RCP-3-705 "Special Maintenance Radiological Control Procedures".
1147 211
- 10 - On May 21, 1979, the inspectors noted that a trailer located to the west of the Unit 1 and 2 auxiliary building was useo for storage of radioactive material.
Radiation levels measured at 1 ft. from the trailer were 2.5 mrem /hr.
A licensee representative stated that the trailer was partially loaded with low level radioactive waste and had been there for a week.
The inspectors note that the trailer a s not posted as a radioactive materials area in accordance,11th 10 CFR 20.203(e)(1), though it contained radioactive material exceeding 10 times the quantity of such materials specified in 10 CFR 20 Appendix C.
The trailer was still at the same location on May 25 and the inspector found it properly posted.
On May 23, 1979, while touring the controlled area, the inspectors noted that the Unit 1 spent fuel pool area was also not posted as a radioactive materials area.
The activity in spent fuel stored in the pool exceeded 10 times the quantities specified in 10 CFR 20 Appendix C.
On May 24, 1979, a storage pad on to the west of auxiliary building was examined.
This pad is normally used to store 55 gal. drums of low level waste.
Though no drums of waste were present other radioactive components were stored there such that maximum dose rates at the fence of the area were 1.5 mrem /hr.
Based on these measurements it was determined that the activity exceeded 10 times the quantities specified in 10 CFR 20 Appendix C.
The inspector identified the above as ;xamples of noncompliance with 10 CFR 20.203(e)(1).
(50-317/78-08-04;50-318/79-07-04).
8.
Surveys The inspector reviewed those surveys performed in conjunction with the following) Radiation Work Permits (RWPs) and Special Work Permits (SWPs : SWP-379A, SWP-215A, SWP-448, RWP-R-79-4, and RWP-R-79-5 to determine ccmpliance with the requirements of 10 CFR 20.201(b).
The inspector also reviewed surveys performed in conjunction with Rad-Chem Procedure RCP-3-601, "Use and Posting of Status Boards", Rev. O dated December 5, 1977.
Independent measurements were made to verify selected licensee radiat4n surveys.
, The inspector noted status boards to be up-to-date and contain adequate survey information.
\\\\47 2\\4
' . . 11 - No items of noncompliance were identified in this area.
9.
Training The inspector reviewed the licensee's training program with respect to the following: 10 CFR 19.12, " Instructions to Workers" -- Calvert Cliffs Instruction. (CCI) 607C, " Radiation Safety -- and Chemistry Personnel Training" Licensee Response to combined Inspector Report No. 50-317/ -- 78-22; 50-318/78-16 The inspector audited the licensee's radiation worker training course used to fulfill the requirements of 10 CFR 19.12.
Training records and examinations given at the end of the training course were reviewed for 14 individuals.
The inspector reviewed training records of selected Radiation Safety and Chemistry personnel with respect to CCI-607C and with respect to the additional information provided in licensee response letter to combined inspection numbers 50-317/78-22; 50-318/78-16.
The review indicated that the training documentr'. ion not available in the aforementioned inspection had been recc<ered and refiled.
The inspector noted the training records to ;ontain the required doct.menta tion.
The inspector indicated to licensee representatives that the item of noncompliance associated with the above inspection report would be withdrawn.
No items of noncompliance were identified k. this area.
1147 2 0
- . - 12 - 10.
Advance Planning and Preparation The licensees radiation protection organization for the refueling outage was as follows: Radiation Safety & C1emistry Engineer I I Plant Health Physicist Performance Engineers (Chemistry, Radiation Control) i Radiation Safety & Chemistry Foreman (Chemistry and Radiochemistry) Radiation Safety & Chemistry Foreman I Principal Technicians Technicians I Radiation Safety Special Maintenance Group Supervisor (Radiation control, dosimetry, support) { l Shift Supervisors I Principal Technicians Technicians Technicians Technical Specification 6.3, " Facility Staff Qualifications", sta tes : "Each member of the facility sta','f 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,he following: "4.5.2 - Technicians Technicians in responsible positions shall have a minimum of two years working experience in their special ty... " - 1147 216
. - _ 33 Many contractor technicians wera used to augment the plant staff. The qualifications of 40 individuals designated as senior technicians and 14 individuals designated as junior technicians were reviewed.
Of the senior technicians 34 met or exceeded the requirements of ANSI N 18.1 1971. The work assignments and amount of supervision these individuals received were reviewed.
It appeared that the individuals were qualified to perfonn their tasks and that no unqualified persons were in positions of responsibility.
11.
Exit Interview The inspectors met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on May 25, 1979. The inspectors summarized the scope of the inspection and the findings.
1147 217 }}