IR 05000317/1993006
| ML20035A051 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/08/1993 |
| From: | Eckert L, Joseph Furia, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20035A048 | List: |
| References | |
| 50-317-93-06, 50-317-93-6, 50-318-93-06, 50-318-93-6, NUDOCS 9303240008 | |
| Download: ML20035A051 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-317/93-06 Report No.
50-318/93-06 50-317 Docket No.
50-318 DPR-53
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License No.
DPR-69 i
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Licensee:
Baltimore Gas and Electric Company Post Office Box 1475 Baltimore. Magland 21203
Facility Name:
QJvert Cliffs Nuclear Power Plant. Units 1 and 2 i
Inspection At:
Lusby. Marvland
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Inspection Conducted:
March 1-5.1993
Inspectors:
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J+O J. Fdria, senior Radiation Specialist, date Facilities Radiation Protection Section (FRPS),
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Facilities Radiological Safety and Safeguards
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Branch (FRSSB), Division of Radiation Safety
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and Safeguard RSS)
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3 -b-D L.'Eckert', Radiation Specialist, FRPS, FRSSB, DRSS date Approved by:
MC 3 -t 't T,
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W. Pasciak, Chief, FRPS, FRSSB, DRSS date Areas Insoected: Announced inspection of the radiation protection program including:
management organization, assurance of quality, radiation control during outage operations,
ALARA, and implementation of the above programs.
l Results: Strong performance in the areas of radiological work control and dosimetry were noted. The program for maintaining radiation exposures as low as reasonably achievable (ALARA) was noted in previous inspections to contain deficiencies. The licensee addressed
the deficiencies, but the success of these corrective actions will be fully evaluated after the l
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Unit 2 refueling outage has been completed. No violations of regulatory requirements were identified. One open item as described in paragraph 2 of the inspection report vas closed.
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9303240008 930311 i
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PDR ADOCK 05000317 l
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DETAILS I
1. Personnel Contacted
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1.1 Licensee Personnel
- P. Chabot, Superintendent, Technical Support
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- R. Franke, Compliance Engineer
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- S. Hutson, Supervisor, Radiation Control - Operations M. Kratz, Senior Technician - Dosimetry
G. Phair, Assistant General Supervisor, Radiation Control and Support t
- C. Sly, Compliance Engineer
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L. Smialek, Health Physicist
- B. Watson, General Supervisor - Radiation Safety
- R. Wyvill, Supervisor, Radiation Control - ALARA j
1.2 NRC Personnel
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F. Lyon, Resident Inspector
- P. Wilson, Senior Resident Inspector
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- Denotes those present at the exit interview on March 5,1993.
2. Previously Identified items (Closed) Violation (50-317/92-13-01; 50-318/92-13-01) Improper waste manifests for five spent resin shipments. The licensee has completed its long term corrective l
actions, including modifications to management guidelines for the Chemistry
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Department and conducting a review of other Chemistry Depanment infrequent tasks.
This item is closed.
3. Radiation Safety j
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Since the last inspection of the Radiation Safety program, the licensee made changes in its supervision of the ALARA (as low as reawr. ably achievable) and Nuclear Plant
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Suppon sections. The former Nuclear Plant Support Supervisor became the ALARA Supervisor, while a Senior Radiation Technician was promoted to the position of Nuclear Plant Support Supervisor. In addition, several Senior Radiation Technicians
were transferred from the Radiation Control - Operations section to ALARA, while i
several Senior Radiation Technicians were promoted to Radiation Control Shift Supervisor. For the Unit 2 refueling outage, contract technicians were added to all
Radiation Safety sections, including 72 technicians in Radiation Control - Operations,
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32 contract laborers in Nuclear Plant Suppon, while additional contract technicians were added in ALARA and Materials Processing, and clerks added to dosimetry.
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These staffing levels appeared adequate to support the refueling outage.
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3.1 ALARA The licensee established a goal of not more than 225 Person-Rem for the Unit 2 refueling outage. Significant dose intensive activities included: Reactor
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disassembly, refueling and reassembly; steam generator primary side maintenance; reactor coolant system insulation replacement; reactor coolant pump motor replacement; shutdown heat exchanger repairs / modifications; and
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reactor coolant pump seal replacement. For all of 1993, the licensee has established a goal of not more than 320 Person-Rem.
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For the Unit 2 outage, which began in mid-February 1993, the licensee augmented its ALARA staff with experienced contractors. The inspector noted that significant time was being spent by the ALARA technicians in setting up
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lead shielding and blankets, rather than in monitoring work in progress. Such monitoring is important to the ALARA process, providing opportunities to identify ways to avoid dose and to funher improve the ALARA process in future activities. During four days of the inspector entering the Radiation i
Controlled Area (RCA), only one ALARA technician was observed conducting field observations of work in progress. Discussions with the ALARA
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supervisor indicated that in future outages ALARA technicians would spend more time conducting field observations, while support personnel would be assigned to shielding installation.
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Outage planning and work control appeared to be improved since the Unit I refueling outage in 1992. Work scope for the outage was frozen prior to the
start of the outage, and the licensee established a Radiation Safety - Planning l
and Scheduling Group to interface with both outage planning and work
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I control. Although the ALARA section has improved its advanced planmng, discussions with the ALARA supervisor indicated that many outage work packages were not completed until after January 1,1993, while the expectation for future outages would be to commence ALARA planning as soon as the i
current refueling outage is completed.
l As part of this inspection, a review of the licensee's 1992 ALARA performance was conducted. At the end of February, the licensee issued its 1992 Annual ALARA Report. This was the earliest issue date for this type of report that the licensee has made in several years. The report summarizes the
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1992 ALARA performance, which included the Spring 1992 Unit I refueling
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l outage. The original 1992 ALARA goal was not more than 230 Person-Rem, with the final total being approximately 40% over the goal at 330 Person-Rem.
The primary cause for this poor performance was the lack of appropriate
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outage planning and work control, as has been discussed in previous inspection reports. In addition, dose estimates for several key outage activities were significantly underestimated by the ALARA section.
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4 The licensee issued in January 1993 its ALARA Five Year Pian, the first such document the licensee has ever produced. This document lists both dose reduction initiatives to be examined by the licensee and also gives estimated completion dates for these evaluations. Of note in this report was that the t'
licensee lists the installation of the reactor cavity neutron shields for Units 1
- d 2 for the 1994 and 1995 outages respectively. This project has been
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ongoing since 1980, and its resolution should result in a significant reduction in site neutron dose, which was 14.678 Rem for 1992. The licensee listed
initiatives such as reduction in the primary letdown filter porosity size, high
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boration shutdowns, hot spot reduction and system decontaminations. Most
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importantly, however, was the inclusion of improving work planning and control, which will significantly reduce the plant exposure during outages.
For 1993, the licensee established a goal of not more than 100 preventable Personnel Contamination Incidents (PCIs), and a rate of not more than 1.00 PCIs per 1000 RCA entries. Through March 4,1993 the licensee had a total of 4 preventable PCIs and a rate of 0.54 PCIs per 1000 RCA entries. In addition, a total of 29 PCIs had been identified,12 during the Unit 2 outage, one involving a contaminated rubber glove worn by one of the NRC inspectors. This PCI, on March 2, was handled by the licensee in a very professional manner.
3.2 Radiation Control As discussed above, the licensee augmented its permanent Radiation Control -
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Operations (RadCon-Ops) staff with 72 contractors for the outage. A total of
75 additional technicians had been authorized, but at the time of this inspection, three had not arrived on site as yet and 8 that were on site had not completed initial and job specific training. The licensee utilizes the general knowledge examination for radiation protection technicians, developed by Northeast r'tilities, to screen its contract technicians.
During 2hi-a, the licensee was concentrating on containment decontamiru
. working on setting up the reactor head for removal.
When the containment was opened following shutdown on February 19, essentially all horizontal surfaces within the containment were found to be covered with a red dust, which was radioactive, and led to millirad per hour
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smearable contamination survey results. At the time of this inspection, no
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final determination had been made by the licensee as to the cause of this problem, although it was theorized that the dust was a rust from the containment coolers, while the contamination came from a primary systems leak discovered on 7 of the 8 in-core instrument (ICI) flanges located inside the reactor head shroud. The contamination represented a significant challenge to the radiation safety staff, especially the Nuclear Plant Support members i
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the reactor head shroud. The contamination represented a significant challenge to the radiation safety staff, especially the Nuclear Plant Support members tasked with area decontamination efforts,
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As part of this inspection, direct observation of work in progress in the Unit 2 containment, especially decontamination efforts in the reactor cavity and the installation of the reactor head lift rig, were made. Despite the complications arising from the presence of the red dust, all decontamination activities conducted in the reactor cavity were accomplished without PCls. RadCon-Ops coverage of work activities, especially the removal of boric acid crystals from the ICI flanges, was generally very good. Job coverage included locating three RadCon-Ops technicians in the reactor cavity to support four decontamination workers. Although this led to some additional doses to the RadCon-Ops technicians, given the unique nature of this work the level of control was appropriate.
During the initial work on the ICI flanges, the RadCon Containment Work Leader (CWL) identified a problem in the placement of dosimetry for the decontamination technicians. During the pre-job briefing conducted between the decon technicians and the RadCon-Ops staff prior to the commencement of work, discussions were held regarding the positioning of dosimetry and the position the workers would be taking relative to the ICI flanges. Based on this discussion, a decision was made by the RadCon-Ops supervisor to have whole body dosimetry placement remain on the trunk of the whole body. During the first 15 minutes of work around the flanges, it became apparent to the CWL that the dosimetry placement was not appropriate, and that special dosimetry, including placement on the upper arms and head was needed. All workers were instructed to leave the cavity, and special dosimetry was secured.
Several hours later a new crew on decon personnel completed the work, wearing the special dosimetry. Licensee actions for this job were determined to be appropriate.
Two issues involving safety, one radiological and the other industrial, were noted by the inspector while observing the installation of the reactor head lift rig. The radiological issue involved a contract RadCon-Ops technician exiting the reactor cavity and removing his respirator and hood while still in containment. This technician then went to the check-in desk in containment and conversed with other technicians for approximately five minutes before exiting the containment. A discussion with the RadCon-Ops Supervisor indicated that it was plant policy to remove respiratory protection and the hood if the person wearing them felt in stress, however the Supersisor's expectations were that in this situation, the technician should immediately leave the containment. The Supervisor discussed this issue with the technician involved and had a further discussion with all RadCon-Ops technicians as to t
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expectations in this area. The second issue involved industrial safety practices of a licensed contractor involved in the installation of the reactor head lift rig.
Contractor personnel were observed working on elevated areas of the reactor head wearing safety harnesses, but not securing the harnesses. In addition, one contractor was observed throwing a box knife to another worker. The licensee indicated at the exit interview that these safety issues would be promptly investigated.
3.3 Assurance of Ouality As part of this inspection, reviews oflicensee self-assessment documents wem made. These self-assessments were made by the licensee in late 1992 in
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preparation for an Institute for Nuclear Power Operations (INPO) assessment of Calvert Cliffs. The assessment was made against INPO guideline 91-014,
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" Guideline for Radiation Protection at Nuclear Power Plants". In addition, the license was in the process of conducting additional self-assessments of its outage performance in radiation safety, utilizing one of the licensee's plant health physicists. The General Supervisor - Radiation Safety also informed the inspector that he had requested several Quality Surveillances for 1993. This is a significant improvement in the use of assessment tools by the Radiation Safety staff.
3.4 Dosimetry As part of this inspection, a review of the licensee's Themoluminescent Dosimeter (TLD) program was undertaken. The licensee changes out its TLDs on a monthly schedule, and thus just prior to the start of this inspection, some 3000 TLDs had been collected from plant workers and were being processed during this inspection. All anomalous data was being actively investigated by the licensee staff, and there were no safety significant issues involved.
The licensee was in the process of upgrading its dosimetry program via the installation of a radiation database system (computer program), to allow for better real time data tracking and trending. Historically, the licensee's real time dosimetry, self-reading pocket chambers, have provided data that was 15% to 20% higher than that determined at the end of the month from the TLDs. This new database system will utilize electronic dosimeters, and allow for tracking of dose to a much greater accuracy when compared to the TLDs.
This system was scheduled for installation in April 1993, with trials to continue through June, prior to full us ;
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i 4. Exit Interview
The inspector met with the licensee representatives denotect in Section 1 at the
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conclusion of the inspection on March 5,1993. The inspector summarized the purpose, scope and findings of the inspection.
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