IR 05000317/1988024
| ML20206F959 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/08/1988 |
| From: | Craig Gordon, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20206F947 | List: |
| References | |
| 50-317-88-24, 50-318-88-24, NUDOCS 8811210413 | |
| Download: ML20206F959 (6) | |
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U.S. NUCLEAR REGULATORY COMISSION
REGION I
Report Nos.
50-317/88 24
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50 315/88-24 Docket Nos.
50 317 50718
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Category C
l License Nos.
DPR-53 Priority
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DPR 69
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Licensee:
Baltimore Gas and Electric Company P. O. Box 1475 L
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Baltimore, Maryland 21203
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Facility Name: Calvert Cliffs Nuclear Power Plant Units 1 & 2
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Inspection At: Lusby, Naryland Inspection Conducted: October 11-13, 1988
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b Inspectors:
L dbRb.
ll TY uw Emergenc,< Preparedness d a 'e C.~Z. g don $8, DRSS Section, FRS S. Peleschak, EPS l
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Approved By:
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y, Chief, EP5, date
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50 pection on October 11-13, 1988 (Report Nos.
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Inspection Summary:
Ins 317788 74 a 50 3187B8 20 t
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Areas Inspected:
Routine, announced safety inspection of the emergency i
preparedness program including review of previously identified inspection i
lindings, changes to the emergency preparedness program, review of
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organization and management control, inspection of independent program i
audits, and inspection of emergency response organization training.
Results: No violations were identified. The Emergency Plan Emergency
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Response Plan implementing Procedures (ERPIP), and the emergency planning
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program are being implemented in a manner to adequately protect public health
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and safety.,
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8311210413 es:1 e PDR ADOCK 05000317 Q
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DETAILS 1.0 Persons Contacted A. Anuje, Supervisor, Quality Audits Unit
V. Bradley, Security Coordinator
J. Carroll, General Supervisor, Quality Assurance
D. Dean, Security Training Specialist R.' Denton, Manager Quality Assurance and Staff Services
J.Dickerson,QualItyAssuranceEngineer T. Forgette, Supervisor, Emergency Planning Unit
i W. Freesland, Supervisor, Safety and Fire Protection A.Vogel,LicensingEngineerSupervisor, Technical Training D. Shaw
Denotes attend;na.e at exit meeting
2.0 1.icensee Actions on Previously '.dentified Items OPEN (50-317/88 04-01 and 50-218/88-05 01) During the loss of annunciator event which occurred on February)1, 1988, the inspector found that some Emergency Action Levels (EAL did not conform to the guidance of NUREG 0654 while others were inappropriate for the levels of intended response. The licensee agreed to evaluate accident related symptoms, events, and compatibility with existing Emergency Operating Procedures.
The licensee established a task force of department representatives from radiation safety, operations training, emergency preparedness, and fuel cycle management to review current EAL's and compare them with the criteria and initiattnq conditions of NUREG 0654. Task force recommendations and EAL revisions were issued to the Plart Operations and Safety Review Cemittee (POSRC) and operations personnel for review and coment.
Following resolution of coments, ERPIP 3.0, "lmodlate
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Actions" was revised to include updated EAL charpes and presented to
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POSRC on September 28, 1988. Theinspectornotedsignificantchangesin
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initiating conditions relative to emergency classific.ations for fission product barrier degradation, radioactivity release, and containment degradation. The changes, which are currently implemented, do not appear to decrease the overall effectiveness of the Emergency Plan. Hcwever, classroom training and performance training (demonstratian by ke;
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response personnel in drills or exercises) has not been ompleted.
CLOSED (50-317/88 04-02 & 50 318/88 05-02)3.0During the loss of annunciator event, a deviation from ERPIP was made by the licensee in that a partial staff augmentation and facility activation in response A Notice of Violation was issued for failure to itolement establish (e to the emergency was authcrized by the Site Emergency Coordinator SEC Emergency Plan Procedures.
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In the licensee's response of April 21, 1988 to the NRC tht:y believed that the actions taken for partial organization and facility activation were satisfactory to meet the intent of ERPIP 3.0,ll activationbut were not strictly in accordance with the procedure. The need for fu following declaration of an Alert classification was emphasized to all departments in training and correspondence and the loss of annunciator Etl. changed as part of the licensee's comprehensive EAL review.
3.0 Changes to Emergency Preparedness Program The inspector reviewed the licensee's records of changes to the Calvert Cliffs Emergency Response Plan Implementing Procedures made during 1987 and 1988.Implementingprocedureswereevaluakorchangeswerenotedinthe Aside from EAL revisions, no ma Plan.
ed during the 1987 exercise and are adequate and up to date.
Page 14 of ina Emergency Response Plan was revised to reflect that of the ERP!P's indicate that in some(or higher) classification.
ERPIP's are to be used at the Alert Review cases initiating conditions also relate to the Unusual Event classification.
The Supervisor, EP Unit stated that the ERP would be clarified to cover all emergency classifications.
l One facility change occurred during 1988 by the addition of the Nuclear Emergency Facility (NEfl located on the first floor conference room of the HEF building.
The Punction of the NEF as an emergency *esponse
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facility is to provide systems engineering and design engineering
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support to the control room and TSC during emergencies beginning at the Alert classification.
These functions have been transferred from the l
i TSC because most engineering staff, supplies, drawings etc. are I
permanently located in the REF and therefore niore readily accessible at
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any time. Comunication links and a separate equipment locker have been i
designated for NEF use during emergencies.
In order to assess its adequacy, NEF capa!:ilities and function should be evaluated during the next scheduled exercise.
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On September 21,1988, the licensee transmitted a letter to NRC l
indicating relocation of the Operations S'upport Center (OSC) inspectors from the South Service Building to the Interim Office Building. The i
j observed the proposed facility and found it to be adequate in size and space. The licensee provided a schedule of dates when the design,
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construction, and transfer of the facility will be completed. Official
use of the new OSC is expected in 1989.
A major upgrade in the licensee's onsite emergency communications system was completed in September 1988.
The system entitled "Emergency ResponseSpeedDialNetwork",providesindividualspeed-dialtelephones for directors, managers comunicators, and key responders in each emergencyresponsefacility.
To ensure comunication efficiency, each phone has speed dialing (two-digit code) end 3-way conferencing.
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The system appears to have the capability to improve information flow
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within and between facilities.
The inspector found that to satisfy the requirements of 10 CFR 50, Appendix E.IV.B. rqarding annual review of the EAL's with State and local authorities.he licenseo schedules annual meetin s with key officials from the Maryland Department of Environment, benter for Radiological Health and Calvert and St. Mary's counties. Such meetings were conducted in 1986 and 1987, out for 1988 the Supervisor,ing made in EPU indicated that the 1988 meeting was delayed due to changes be z
i the EAL scheme, and e'sected the meeting to be held sometime in November 1988.
a 4.0 Independent Reviews / Audits Independent quality assurance reviews of the EP Unit are performed by the Qualitv Audits Unit and have been adequately conducted to meet the
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j t equirements of 10 CFR 50.54(t ). The inspector reviewed the results of i
audits conducted during 1986 and 1987 and discussed the preliminary l
fi.1 dings of the 1988 audit with EP ard QA staffs.
Specific checklists were used by the QA staff to perform the audits in 1986 and 1987.
In 1988, the checklists were supplemented by INP0 guidance and resulted in a more comprehensive p/ gram audit.
ro The inspectors reviewed the upgraded audit criteria checklist and noted
j that auditors must interpret NRC rules if those items of the checklist i
which relate to key EP program areas are to be used. For other
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programmatic areas, audit criteria are directly associated with the planning standards of 10 CFR 50.47 fb) by auditors could be consideredAny and 10 CFR 50, Appendix E.
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findings or recommendations identifled
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either as items of non-compliance or violations of NRC requirements.
The inspector found that the checklist design is in need of i
i clarification for those items which auditors have linked to NRC rules.
j Further, discussions with members from the QA staff and EP staff revealed that a difference of opinion exists in the manner in which
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review criteria are to be applied.
Tne licensee has maintained in effect an Emergency Plan and EP program to satisfy NRC regulations. The inspector explained that it was necessary for both EP &nd QA staffs to concur in what criteria would be used to perform future audits.
The Manager QA & SS, who has authority overbothUnits,agreedthatimprovedcoordInationbetweenthetwo staffs was needed and indicated that review criteria at:eptable to each Unit would be identified.
Results of audits identified only minor EP Unit deficiencies.
A corrective action system is in place to resolve program deficiencies and the actions taken by the EP staff appeared timely and technically adequate.
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Findings and recommendations are discussed by the auditor with the QA Supervisor and senior auditor. This appears to be the only A management involvement since results are transmitted directl from the auditor to the Supervisor, EP Unit. The inspector noted tha although QA management maintains the statur of open items within its Unit,QA Unit reports do not receive authorization from either the Supervisor, or General Supervisor, QA prior tn issuance.
5.0 Organization and Management Control The inspector held discussions with cognizant licensee management and reviewed documents on the emergency response organization and emergency preparedness program management. The inspection also focused on interfaces and coordination between onsite offsite, and corporate organizations and adequacy of management effectiveness.
Reorganization of the Nuclear Energy Division (NED) resulted in a change in reporting chain of the EP Unit. Ur 4 r the new organization the EP Unit will report to the Vice President, NED through the Radiation Safety General Supervisor and QA & SS Manager.an additional lovel of manap:rment i Although this change the Manager, QA & SS stated that upper level management attention and support for the EP Unit would continue.
A licensee Facility Change Request (FCR) has been made to remove the organization charts from the technical specifications to the FSAR. This will designate the FSAR as the controlling document for future changes of the onsite organization and subject any change to FSAR review.
6.0 Knowledge and Performance of Duties The inspectors reviewed the licensee's program for emergency response training and noted that Attachment 1 of ERPIP 5.4 identifies a training matrix of specific initial training for Pferent categories of directors, and team mem' vers for techn(SEC),ganization personnel within the Emergency Response Or Thest include Site Emergency Coordinators emergency response facility ical support, dose assessment, radiation surveys, inplant repair, first aid and rescue, and chemistry.
Discussions were held with the Technical Training Unit jTTU Supervisor who provided training lesson plans, examination material, ex) amination results, and attendance records of site personnel. Composite training records are maintained via the TTU database files. The TTU conducts General Orientation Training for new )ersonnel and site visitors.
Onsite ERO training is shared among tie TTU, EP Unit, and Operations Training Unit as follows:
The EP Unit is responsible for training of key FR0 personnel ante prcviding instruction in emergency classification, protective action recommendations, technical support, and immediate actions training; the TTU is responsible for inplant team training including teams to carry
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out onsite/offsite surveys, chemistry, first aid and dosimetry.
Both Units provide classroom training in the radiologlcal assessment area.
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Training of offsite fire departments and local law enforcement personnel
respectively.y the Safety and Fire Protection Unit and Security Unit is provided b At least three individuals are qualified in each ERO Following interviews (3)ith the Supervisor, TTU the inspectors potition.
w determined that the background and experience cf instructors appeared
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ad(quate to provide most ERO instruction. Instructors, who are most i
conducting walkthroughs,
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knowledgeable about implementing procedures, ills and exercises only as and developing scenarios, are used during dr controllers or observers and do not participate as responders. Since j
instructors are considered qualified to function in many different response roles, the inspectors discussed with the Supervisors EP Unit
and TT Unit, the possibility of designating training instructors as part
of the ERO and provide them the opportunity to participate in drills and exercises.
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Lesson plans are detailed and focus on important response elements or implementing procedures.
Self-study guides are used to supplement
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lesson plans to provide refresher training for inplant teams.
Practical factor checklist. which require individuals to perform specific tasks associated with their response function are also used for offsite
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monitoring post-accident sampling, and dose assessment teams during
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n pect on o 1c e training records indicated that they were
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complete and up to date.
Exam questions relate directly to lesson plan material.
The ins ectors reviewed results of ERO training performed in examin(ees, i.e., a 1 scores exceeded) and noted a 100% pass rate of all 1988 approximate 1 300-400 records
the 80% passing criteria.
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Although performance of response personnel has consistently been demonstrated in drills and walkthrough exercises, the inspector
i questioned whether or not administration of exams is meaningful given
the high pass rate. The TT Unit Supervisor sta'ed that training materials would be evaluated to make ex minat. ions m:,re challenging, u
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7.0 Exit Meeting
l The inspectors met with the ir see personnel denoted in Section 1 at the conclusion of the inspection to discuss tha findings as present i in
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this report.
The inspectors also discussed same areas for improver.it, j
The licensee acknowledged the findings and ar, reed to evaluate them and institute corrective actions as appropriate.
I At no time during the inspection did the inspectors provide any written information to the licensee, i
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