IR 05000317/1979013
| ML19296D224 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/15/1979 |
| From: | Plumlee K, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19296D213 | List: |
| References | |
| 50-317-79-13, 50-318-79-10, NUDOCS 8003030032 | |
| Download: ML19296D224 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND EtlFORCEMENT Region I 50-317/79-13 Report No. 50-318/70-10 50-317 Docket No. 50-318 DPR-53 C
License No. DPR-69 Priority Category C
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Licensee:
Baltimore Gas and Electric Comoany P. O. Box 1475 Baltimore, Maryland 21203 Facility Name:
Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection at:
Lusby, Maryland Inspection conducted. uly 30 - August 2, 1979
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Inspectors:
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K. Plumlee, Radiation Specialist date signed date signed date sign d Approved by:
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J.f. SfohrTChief, Tadiation Support Section, date signed '
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VF&f15 Branch Insoection Summary:
Inspection on July 30 - August 2, 1979 (Report Nos. 50-317/79-13 and 50-318/79-10 Areas Inspected:
Routine, unannounced inspection by a regional based inspector of radiation protection during operation of Unit 1 and an unscheduled maintenance outage of Unit 2, including:
adherence to procedures; exposure control; posting, labelling and control of radiation hazards; posting of notices; and notifications and reports.
Upon arrival at the facility, a tour was conducted to permit observation of radiation protection practices.
The inspection involved 32 inspector-hours on site by one regional based NRC inspector.
Results:
Of the five areas inspected, no items of noncompliance were identified in three areas. Twc items of noncompliance and one unresolved item were identi-fied in two areas (Deficiency - failure to post documents and notices required by 10 CFR 19.11, Paragraph 2.a. and b. Infraction - failure to control access to contaminated areas as required by procedures, Paragraph 3; Unresolved -Posting of Form NRC-3's in frequented portions of Restricted Area, Paragraph 2.c.).
Region I Form 12 (Rev. April 77)
80030"
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DETAILS 1.
Persons Contacted
- M. Bowman, Supervisor, Quality Assurance Auditing Unit
- J. Carlson, Radiation Safety and Chemistry Foreman
- J. Carroll, Supervisor, Technical Support
- P. Crinigan, Radiation Safety and Chemistry Engineer (Alternate)
A. Kaupa, Radiation Safety and Chemistry Engineer J. Lenhart, Principle Radiation Safety and Chemistry Technician
- E. Reimer, Plant Health Physicist
- L. Russell, Chief Engineer J. Speciale, Radiation Safety and Chemistry Foreman
- R. Wenderlich, Training Coordinator
- C. Woody, Assistant General Supervisor
- J. Yoe, Training Specialist
- denotes those present at the exit interview, August 2, 1979.
2.
Review of Compliance with Requirements of 10 CFR 19, " Notices, Instruc tions, and Reports to Workers:
Inspections" a.
" Restricted Areas" The definition of " Restricted Area" given in 10 CFR 19.3, as well as in 10 CFR 20.3, is:
" Restricted Area" means any area access to which is controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive mater:als."
After previous discussions o. iring the inspection, a licensee represen-tative stated during the exii interview that the entire 1136 acre r.te is the " Restricted Area.* This information is evident in the FSAR and in procedures.
b.
Posting of Notices to Workers Posting requirements given in 10 CFR 19.11 " Posting of N]tices to Workers" includes, in part:
"(a)
Each licensee shall post current copies of the following documents:
(1) The regulations in this part and in Part 20 of this chapter; (2) the license, license conditions, or documents incorporated into a license by reference, and amendmer.ts thereto; (3) the operating procedures applicable to licensed activities;...
(b)
If Posting of a document specified in paragraph (a)(1),
(2), or (3) of this section is not practicable, the licensee may post a notice which describes the document and states where it may be examined...
(d) Documents, notices, or forms posted pursuant to this section shall appear in a sufficient number of places to permit individuals engaged in licensed activities to observe them on the way to or from any particular licensed activity location to which the document applies, shall be conspicuous, and shall be replaced if defaced or altered."
The licensee representative stated that the above documents were not posted as it was not practicable, and a notice was posted pursuant to the provisions of 10 CFR 19.ll(b).
The inspector observed that only a single typewritten page, dated 1973, was posted.
This notice described 10 CFR 19 and 10 CFR 20, but did not describe any of the following:
Reactor Operating License No. DPR-53, issued July 31, 1974.
Reactor Operating License No. DPR-69, issued August 13, 1976.
Reactor license conditions.
Documents incorporated into Reactor Operating Licenses by reference.
Amendments to Reactor Operating Licenses.
Reactor Operating procedures.
The inspector observed that the posted notice was indoor at the east wall of the Turbine Building, near an entrance to a lunch room.
This place was far from the security posts through which individuals go to and from trailers, administrative offices, the Auxiliary Building, the Control Room, and other places within the fenced area wherein the Turbine Building is located.
The inspector observed that an individual going directly to and from licensed activities at typical locations inside this fenced area could not examine the notice where it was placed.
Furthermore, the licensee representatives concurred that several individuals, who were not badged to enter this fenced area, worked in other portions of the Restricted Area where there was no opportunity to examine this single posted notice.
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The inspector observed that the notice described a byproduct nc+erials license and a special nuclear materials license, both of which had terminated on issuance of Reactor Operating License No. DPR-53, five years before this inspection.
The licensee representative did not identify any previous assignment of responsibility to keep the posted information current.
The inspector stated that failure to post the required information in accord with 10 CFR 19.11 n s an item of noncompliance (317/79-13-1 and 318/79-10-1).
c.
Pcsting of Form NRC-3's A further requirement of 10 CFR 19.11 is:
"(c) Form NRC-3, " Notice to Employees," shall be posted by each licensee wherever individuals work in or frequent any portion of a restricted area."
The inspector observed as he entered the 1136 acre " Restricted Area," there was no posted current Form NRC-3 and no notice at any point on the public road, along the access road, and on entering various parking lots and the Overlook, that this area is controlled for purposes of protection of individuals from exposure to radiation and radioactive materials.
Individuals are routinely assigned groundskeeping, attendant, and security activities within these portions of the " Restricted Area," and unescorted visitors and tourists may be present at the Overlook.
The inspector observed that current Form NRC-3's were posted in the Turbine Building and also at the entrance to the Control Room and the Auxiliary Building, but not in several other portions of the
" Restricted Ar!1."
This item is unresolved pending a review of licensee resolution of this matter including his designation of the " restricted area" on a sutsequent routine inspection (317/79-13-2 and 318/79-10-2).
3.
Control of Access to Contaminated Areas
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The inspector stated on arrival, July 30, 1979, the intent to tour the facility, including the readily accessible stairs and walkways.
During a tour of the Unit 2 containment on August 1, the licensee representative refused entry to the lowest level.
The inspector observed there was no barricade, posted sign, stepoff pad, or other visible indication of any different hazard on the lowest level than on the level where they were
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standing and, in fact, the airflow was coming up through the open stairway leading to the lowest level.
The licensee representative stated that a respirator was necessary to tour any part of the lowest level and the inspector was not to take even one step down the stairway without a properly fitted respirator.
The licensee representative stated there was such a contamination potential on the stairway to the lowest level, and on the lowest level, that a respirator was specified.
On August 2, 1979, the inspector was permitted a limited tour of the lowest level, wearing a fitted respirator.
The inspector observed, on descending the stairway and touring along the walkway on the lowest level, that he could approach and examine stepoff pads, stands, ropes, barricades, and signs warning of hazards beyond those points, but there were no visible warnings or controls on either the stairway or the walkway for a distance of 30 to 40 feet in either direction different from hazards er controls required on other levels of containment toured without a respirator.
The inspector observed that on completion of the August 2,1979 tour of containment, the shoe covers (rubbers) worn on the lowest level of con-tainment were placed back in the barrel from which they had been taken.
The licensee representative admitted that these rubbers, after being worn on the lowest level, were likely to be worn anywhere in containment by the next user without any required check for contamination.
The inspector examined all of the records made available to him of recent air samples and surveys in diff; rent levels of containment.
No difference of any consequence was indicated in the airborne radioactivity levels and in the floor contamination of the areas toured without respirators on August 1, 1979, as compared to areas toured on August 2, 1979, wearing respirators.
The licensee representative stated during the exit interview that. the stairway and containment lowest level were treated as a more contaminated area within a larger less contaminated area, and still more contaminated areas existed beyond this area.
The inspector noted that Technical Specifications, Section 6.11, " Radiation Protection Program," requires:
" Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure."
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The licensee's Radiation Protection Manual, developed pursuant to the above, as well as other licensee procedures, require the delineati.on of established airborne radioactivity and contaminated areas with signs, stands. repos, and/or barricades and maintenance of stepoff pads on exiting these areas.
The inspector noted that no visible delineation of this cotstaminated area was maintained on August 1 and 2, 1979, and this failed to comply with the above requirements (318/79-10-3).
There were several adequately controlled airborne radioactivity and contaminated areas on the lowest level of containment.
4.
Dosimetry Records Routine review of recent dosimetry records available during the period of July 21-27, 1979, did not identify any problems or omissions.
Review of Form NRC-4's and Form NRC-5's did not identify any problems.
5.
Work Permits Ob. vation of personnel working on RWP's and SWP's did not identify any problems during tours of the facility.
Surveys prior to issuing work permits generally appeared acceptable.
6.
Notifications and Reports Review of records maintained of notifications and reports to individuals and to NRC did not identify any problems.
7.
Management Exit Interview The inspector met with licensee management representatives (denoted in Paragraph 1) at the conclusion of the inspection of the facility, August 2, 1979.
(Further interviews were conducted of other personnel following the exit interview.)
The inspector summarized the scope and findings of the inspection as presented in this report including the items of noncompliance and un-resolved item.