IR 05000317/1993022
| ML20024J026 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/13/1993 |
| From: | Larry Nicholson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20024J023 | List: |
| References | |
| 50-317-93-22, 50-318-93-22, NUDOCS 9308310164 | |
| Download: ML20024J026 (16) | |
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U.S. NUCLEAR. REGULATORY COMMISSION REGION 1 Report Nos.
50-317/93-22; 50-318/93-22 License Nos.
DPR-53/DPR-69
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Licensee:
Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203 Facility:
Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location:
Lusby, Maryland Inspection conducted:
July 4,1993, through August 7,1993 Inspectors:
Peter R. Wilson, Senior Resident Inspector Carl F. Lyon, Resident Inspector Henry K. Lathrop, Resident Inspector Approved by:
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b Larry,,5^Nicholson, Chief Date React 6r Projects Section No. lA Division of Reactor Projects Inspection Summary:
This inspection report documents resident inspector core, regional initiative, and reactive inspections performed during day and backshift hours of station activities including: plant operations; maintenance; engineering; and plant support.
_Rfsults:
See Executive Summary.
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9308310164 930820 PDR ADDCK 05000317
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EXECUTIVE SUMMARY
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Calvert Cliffs Nuclear Power Plant. Units 1 and 2 l
InSDection Report Nos. 50-317/93-22 and 50-318/93-22 j
Plant Operations: (Operational Safety Inspection Module 71707, Prompt Onsite Response to
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Events at Operating Power Reactors Module 93702). Both units operated without significant events during the period. The Plant Operations and Safety Review Committee effectively executed their Technical Specification responsibilities.
i Maintenance: (Maintenance Observations Module 62703, Surveillance Observations Module j
61726)
BG&E had properly implemented a Limiting Condition for Operation (LCO)
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maintenance program that effectively minimized equipment out-of-service time.-
During maintenance on a service water heat exchanger, the inspectors identified several problems, including continuing concerns with BG&E's implementation of foreign material exclusion j
controls, supervisory control of activities and failure to follow a maintenance procedure. The failure to follow the procedure was a non-cited violation.
- Ennineerine: { Module 71707) BG&E's response to a hydrogen leak on the Unit 2 main
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generator was charterized by a prompt evaluation and a good questioning attitude, with due j
regard for equipment el personnel safety.
Plant Suonort: (Module 71707)
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Radiological Controls - Overall, an excellent level of performance in routine activities j
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was observed. On'one occasion, however, an engineer who had not received radiation training improperly entered the Radiologically Controlled Area. This was a non-cited I
violation.
l Emergency Preparedness - The inspectors had no noteworthy findings in this area.
- Security - Areas of security program implementation were satisfactory.
- Plant Chemistry - Primary and Secondary water chemistry was maintained within
Technical Specification and procedural limits. No unacceptable conditions were noted.
Fire Protection - No unacceptable conditions were noted.
Housekeeping - General plant housekeeping was excellent except for the circulating / salt water intake structure and the Unit 2 service water room. BG&E was correcting these deficiencies as the period ended.
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TABLE OF CONTENTS PAGE EXECUTIVE SUMMARY......................................ii 1.0 SUMMARY OF FACILITY ACTIVITIES I
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2.0 PLANT OPERATIONS
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2.1 Operational Safety Verification........................... 1 2.2 Followup of Events Occurring During Inspection Period
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2.3 Plant Operations and Safety Review Committee................. 2 3.0 MAINTENANCE
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3.1 Maintenance Observation...
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3.2 21 Service Water Heat Exchanger Tube Cleaning................ 3 3.3 LCO Maintenance................................... 4 4.0 ENGINEERING
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4.1 Hydrogen Leak on Unit 2 Main Generator.................... 6 5.0 PLA NT S U P PO RT........................................ 7 5.1 Radiological Controls................................. 7 5.2 Emergency Preparedness..............................
5.3 Secu ri ty........................................
5.4 Plant Chemistry...................................
5.5 Fire Protection.
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5.6 Housekeeping.....................................
6.0 REVIEW OF WRITTEN REPORTS...........................
7.0 FOLLOWUP OF PREVIOUS INSPECTION FINDINGS..............
7.1 (Closed) Violation 92-25-01: Improper High Radiation Area Entries...
8.0 MANAGEMENT MEETING
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8.1 Preliminary Inspection Findings
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8.2 Attendance at Management Meetings Conducted by Region Based I n spect ors......................................
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DETAII S
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1.0 SUMh1ARY OF FACILITY ACTIVITIES Unit 1 began the period at full power. On July 18, operators reduced power to approximately l
55% and the 11 steam generator feed pump was removed from service to repair a ground on a remote overspeed trip circuit. The unit returned to full power on July 19 and completed the
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period without incident.
I Unit 2 began the period at full power. The operators removed the unit from the grid on July
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17 to repair a leak in the hydrogen supply line to the main generator. The leak is discussed in
section 4.1. The unit returned to full power on July 19 and operated without incident for the
remainder of the period.
l 2.0 PLANT OPERATIONS
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2.1 Operational Safety Verification
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The inspectors observed plant operation and verified that the facility was operated safely and in j
accordance with licensee procedures and regulatory requirements. Regular tours were conducted
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of the following plant areas-
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- control room
-- security access point
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- primary auxiliary building-
-- protected area fence l
- radiological control point
--intake structure
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- electrical switchgear rooms
-- diesel generator rooms
- auxiliary feedwater pump rooms
-- turbine building
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Control room instruments and plant computer indications were observed for correlation between j
channels and for conformance with technical specification (TS) requirements. Operability of l
engineered safety features, other safety related systems and onsite and offsite power sources was
verified. The inspectors observed various alarm conditions and confirmed that operator response was in accordance with plant operating procedures. Compliance with TS and implementation l
l of appropriate action statements for equipment out of service was inspected. Plant radiation
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monitoring system indications and plant stack traces were reviewed for unexpected changes.
Logs and records were reviewed to determine if entries were accurate and identified equipment status or deficiencies. These records included operating logs, turnover sheets, system safety tags
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and temporary modifications log. The inspectors also examined the' condition of meteorological'
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and seismic monitoring systems. Control room and shift maaning were compared to regulatory l
requirements and portions of shift turnovers were observed. The inspectors found that control I
room access was properly controlled and that a professional atmosphere was maintained.
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In addition to normal utility working hours, the review of plant operations was routinely
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conducted during backshifts (evening shifts) and deep backshifts (weekend and midnight shifts).
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Extended coverage was provided for 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> during backshifts and 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> during deep backshifts. Operators were alert and displayed no signs of inattention to duty or fatigue.
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The inspectors observed an acceptab:e level of performance during the inspection tours detailed above.
2.2 Followun of Events Occurring During inspection Period There were no significant operational events during the period.
2.3 Plant Operations and Safety Review Committee l
The inspectors attended several Plant Operations and Safety Review Committee (POSRC)
meetings. They verified that the PORSC met the TS 6.5 requirements for required member attendance. The meeting agendas included procedural changes, proposed changes to the TS, Facility Change Requests, and minutes from previous meetings. Overall, the inspectors found
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i that the level of review and member participation was adequate in fulfilling the POSRC
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responsibilities.
3.0 MAINTENANCE l
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3.1 Maintenance Observation l
I The inspector reviewed selected maintenance activities to assure that:
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the activity did not violate technical specification limiting conditions for operation and l
that redundant components were operable;
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required approvals and releases had been obtained prior to commencing work;
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procedures used for the task were adequate and work was within the skills of the trade;
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activities were accomplished by qualified personnel;
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where necessary, radiological and fire preventive controls were adequate and implemented;
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quality verification hold points were established where required and observed; and
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equipment was properly tested and returned to service.
The work observed was performed safely and in accordance with proper procedures. Inspectors l
noted that an appropriate level of supervisory attention was given to the work depending on its priority and difficulty.
Notable observations are included below for selected activities.
Maintenance activities reviewed included:
MO 29300300 Clean 21 service water (SRW) heat exchanger tubes
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MO 29303335 Install thermowells in 21 SRW heat exchanger
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MO 29300323 Clean 21 component cooling water (CCW) heat exchanger tubes MO 19302718 Clean 11 SRW heat exchanger tubes MO 19302736 Clean 21 CCW heat exchanger tubes MO 19300923 Install Kiene indicator valves on 11 emergency diesel generator (EDG)
j MO 19204303 Repair leak on fuel oil filters on 11 EDG
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MO 19201178 Replace bushing on 11 EDG lube oil thermocouple 11-DLO-4779-TC 3.2 21 Service Water Heat Exchanger Tube Cleaning The inspectors noted several deficiencies while observing BG&E maintenance personnel cleaning i
the tubes in the 21 service water heat exchanger (SRWHX). The controlling document for
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performing the work was maintenance order (MO) 29300300. The deficiencies observed j
included performing procedure steps out of order, performing a procedure step incorrectly, and j
failing to meet the prescribed foreign material exclusion control requirements.
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MO 29300300 directed the maintenance personnel to clean the SRWHX tubes according to Calvert Cliffs Nuclear Power Plant Technical Procedure SRWHX-02, " Service Water Heat Exchanger Tube Cleaning." SRWHX-02 Step 2.4 stated that all steps within a subsection must be perform d in their given sequence unless otherwise noted in the procedure body. The inspectors noted that the workers performed Step 6.2.4 (opening the SRWHX manways) prior to performing Step 6.1.2 (setting up and posting the foreign material exclusion area boundary).
The inspectors did not identify any foreign material in the SRWHX because of performing these steps out of order.
5srNHX-02 Step 6.2.7 required the heat exchanger end plate nuts be loosened and removed using a crisscross pattern. The inspectors observed a maintenance supervisor loosening and removing the nuts in a circular pattern. The inspectors did not identify any damage to the end plate or the fasteners because of performing the step incorrectly.
SRWHX-02 required that foreign material be controlled in accordance with Calvert Cliffs Instruction (CCI) 206, " Foreign Material Controls." The inspectors reviewed the foreign material controls specified for the above work activity. The CCI-206 foreign material controls checklist required, in part, that personnel remove loose articles from their pockets. On two occasions the inspectors observed personnel (the maintenance supervisor and a system engineer)
within the clean area boundary with loose articles in their pockets. The inspectors did not identify any foreign material that was introduced into the SRWHX as a result of this deficienc.
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The failure to adequately implement foreign material control requirements is a continuing problem. In May 1992 and again in November 1992, the inspectors identified several instances where BG&E failed to rigorously implement the site procedure for foreign material exclusion control (see NRC Inspection Reports 50-317 and 318/92-15 and 50-317 and 318/92-27). One of the prior instances also involved a maintenance supervisor.
The inspectors discussed the above issues with the Superintendent-Nuclear Maintenance (S-NM).
The S-NM subsequently conducted a review of these deficiencies. As a result of this review, BG&E has revised SRWHX-02 to provide some flexibility by annotating steps that did not have to be performed in sequence, and removing the requirement to loosen and remove the end plate nut in a crisscross pattern. The S-NM also stated that the foreign materials checklist was overly conservative for this specific service water application and that it would be revised. The inspectors concurred with this assessment.
The key issue remaining was that the personnel involved, and particularly the maintenance siipervisor, did not rigorously follow the requirements of SRWHX-02 or the CCI-206 foreign materials control checklist. The S-NM informed the inspectors that the individuals involved received counseling to correct this problem.
In summary, there were no safety consequences as a result of the above deficiencies because no foreign material was introduced into the heat exchanger and no components were damaged.
BG&E's corrective actions for these specific deficiencies were adequate.
However, the inspectors remained concerned that the implementation of foreign material exclusion controls continued to be a weakness with maintenance personnel and their supervision.
TS 6.8.1.a requires that applicable procedures be implemented as recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33 requires that maintenance that can affect the performance of safety-related equipment be performed in accordance with written procedures. Therefore, the failure to properly follow the procedure steps in SRWHX-02 was a violation. The failure to meet TS 6.8.1.a was not cited because the criteria specified in Section Vll.B. of the NRC Enforcement Policy were satisfied.
3.3 1.CO Maintenance In May 1993, BG&E implemented their Limiting Condition for Operation (LCO) maintenance program. The purpose of the program was to minimize the time components required by TSs
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were voluntarily removed from service to perform certain maintenance activities. These l
maintenance tasks included preventive maintenance, minor corrective maintenance, and the
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installation of minor modifications. The inspectors conducted a review of the program to evaluate its effectiveness and to determine if BG&E implemented the program properly. The evaluation consisted of document reviews, field observations, and interviews with maintenance
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personnel, system engineers, and maintenance and system engineering managers. The purpose i
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was to determine that when BG&E took equipment out of service to perform maintenance during
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power operation there was an improvement in reliability of the equipment, to reduce overall l
safety risk.
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BG&E documented the LCO maintenance program requirements in Calvert Cliffs Nuclear Power l
Plant Administrative Procedure MN-1-202, " Conduct of Plant Work Control. The inspectors.
j found that the program consisted essentially of two parts. The first part required the responsible system engineer to make a determination that the LCO maintenance activities were necessary to i
maintain or improve equipment reliability and/or availability. The program also required the
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system engineer to develop contingency plans when the scheduled duration of the activity would
_f exceed 50% of the allowable LCO time. The second part of the program contained several l
requirements to minimize the time the equipment was out of service.
This included
consideration of resources available to perform the work, prestaging of tools at the job site, i
building necessary scaffolding and conducting a pre-job walkdown. MN-1-202 also contained l
a check list to be included in each work package that BG&E considered to be LCO maintenance.
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from service to ensure that the above objectives were met.
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On July 21 and 28, the inspectors observed ten LCO maintenance activities. These activities were associated with BG&E's Quarterly System Schedule (QSS) (a rolling 12 week sequence of plant system scheduling windows for conducting non-outage work). The major activity of the i
observed QSS maintenance involved the tube cleaning of service water heater exchangers (LCO i
maintenance). In order to perform this maintenance, BG&E also had to remove the associated
safety train from service (i.e., emergency core cooling pumps, emergency diesel generator, component cooling water heat exchanger, etc.). With the safety train removed from service, BG&E performed several additional LCO maintenance activities on these systems.
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With only one exception, the inspectors found that BG&E met the LCO. maintenance program i
requirements as set forth in MN-1-202. The one exception involved the work performed under maintenance order (MO) 19208319 to install a guard on the 11 emergency diesel generator (EDG) room supply fan. Since the supply fan had to be removed from service and the EDG required the fan for operability, BG&E designated this work as LCO maintenance. The MN-1-202 checklist required the responsible maintenance supervisor to verify that all items necessary for the performance of the job were ready, including the erection of scaffolding prior to'
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l removing the component from service. The inspectors observed that the scaffold for this MO l
had not been built prior to removing the supply fan from service. Also, the maintenance l
supervisor had not completed the LCO maintenance checklist prior to the commencement of work. The inspectors concluded that this was only a minor discrepancy.
Because' the installation of the fan guard was completed several hours before other LCO maintenance activitics on the EDG were completed, this maintenance activity had no impact on the EDG unavailability.
The inspectors found that MN-1-202 did not provide any guidance or criteria to determine the safety improvement gained by accomplishing the LCO maintenance activities. They questioned
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the responsible system engineers on the basis (safety improvement) for performing the obsen'ed LCO maintenance activities during power operation. The system engineers stated that they used engineering judgment and vendor recommendations as the bases.
The inspectors discussed this observation with the General Supervisor-Plant Engineering Section (GS-PES). The GS-PES stated that guidance was not necessary since for the last several years i
engineering judgment and vendor recommendations had been successful in identifying those maintenance activities that significantly improved safety equipment reliability and/or availability.
The GS-PES provided the inspectors with data indicating that since 1990 the unavailability of
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safety systems markedly decreased. The inspectors have observed this improvement, but were I
unable to determine if it was due to the LCO maintenance program or other maintenance initiatives. In conclusion, with the one exception noted above, the inspectors found that BG&E's j
LCO maintenance program was implemented properly, and was effective in minimizing the time
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equipment required by technical specifications was out of sen' ice.
4.0 ENGINEERING 4.1 Hydrogen Leak on Unit 2 Main Generator On July 7, operators discovered a leak in the 1.5 inch hydrogen supply line to the Unit 2 main generator. BG&E determined the leak to be from a crack approximately 0.4 inches long in the socket welded connection where the line penetrated the generator. When discovered, the leak rate was approximately 3000 SCFD. Operators discovered the leak while investigating an
increase in the frequency of charging hydrogen to the generator. BG&E immediately began
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frequent monitoring of the leak site for hydrogen accumulation and evidence of continued crack propagation, and put temporary ventilation in place to dispel the hydrogen. Initial monitoring revealed no accumulation or rise in hydrogen levels in the area.
The immediate concerns over the leak were for personnel safety due to the potential accumulation of hydrogen, the potential of a catastrophic failure of the line, and the possibility of a hydrogen fire or explosion. The hydrogen system is designed to provide cooling to the main generator. It is a non-safety related system with a normal operating pressure of about 75 psig.
BG&E's preliminary evaluation concluded that the hydrogen line had suffered a fatigue crack due to vibration. Initial measurements of vertical displacement on the pipe were about 15 mils.
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Horizontal displacement was negligible.
While BG&E was conducting their preliminary evaluation, however, the hydrogen concentration at the leak site began to rise.
Due to the urgency of the situation, BG&E promptly installed a soft patch on the crack and pipe I
supports to reduce vibration and stop the crack propagation. The temporary alteration (TA 2-93-055) was discussed between plant and design engineering sections and verbally agreed upon.
The TA was then discussed with the Plant General Manager, who approved the installation. The j
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concurrence process was in accordance with Calvert Cliffs Instruction (CCI) 117, " Temporary Modification Control." However, CCI 117 required written documentation of the evaluation and approval prior to TA installation. BG&E documented the TA in memoranda as it was done, then followed up the next day with the documentation required by the CCI. Inspectors discussed this decision with BG&E management and concurred that it was safe and prudent in view of the exigency of the hydrogen leak. An issue report was written to document the process and evaluate CCI 117 for possible enhancement to cover similar situations in the future.
Following installation of the pipe supports and soft patch on the leak site, vibration was reduced to approximately 3 mils. The hydrogen leak rate was reduced to about 900 SCFD with no accumulation or rise in hydrogen levels at the break. BG&E continued frequent monitoring and increased ventilation at the leak site.
On July 17, the unit was removed from the grid and a permanent weld repair of the leak was made. In addition, a permanent support was put on the pipe to reduce vibration. Unit 2 returned to full power on July 19.
Inspectors reviewed the engineering evaluation and calculations which documented the TA. No discrepancies were noted, and good engineering judgment was used. Inspectors assessed that operators had shown a good questioning attitude in identifying the leak, and that BG&E's response was prompt and decisive, with due regard for safety.
5.0 PLANT SUPPORT 5.1 Radiological Controls During tours of the accessible p1 int areas, the inspectors observed the implementation of selected portions of the licensee's Radiological Controls Program. The utilization and compliance with special work permits (SWPs) were reviewed to ensure detailed descriptions of radiological conditions were provided and that personnel adhered to SWP requirements. The inspectors j
observed that controls of access to various radiologically controlled areas and use of personnel monitors and frisking methods upon exit from these areas were adequate. Posting and control I
of radiation areas, contaminated areas and hot spots, and labelling and control of containers holding radioactive materials were verified to be in accordance with licensee procedures. Health Physics technicians performed well in the control and monitoring of day to day activities. In general, personnel performance in this area was also good, except as noted below.
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Improper '
'n the Radiological 1v Controlled Area Inspectors res
<cu nstances surrounding an improper entry into the Radiologically luly 9 by a contract engineer who had not completed General Controlled A'
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Part 2 for radiation workers. GOT Part 2 provided indoctrination
.or personnel requiring access to the RCA.
in radiological y e
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The engineer had received GOT Part I training in November 1992. Since his normal work area was outside the Protected Area and did not involve routine entry to the RCA, he was not given GOT Part 2. However, the individual had been a qualified radiation worker at other facilities.
He was issued a plant identification badge with a yellow background to signify unescorted access
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to only non-Radiologically Controlled Vital Areas.
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On July 9, the engineer entered the Auxiliary Building to inspect a pump while preparing a minor modification package. It was his first entry into the RCA since reporting on site. He was accompanied by a more senior contractor enginer who was properly qualified and authorized to enter the RCA. The engineers logged into the dosimetry record and checked in with the special work permit coordinator (SWPC). The SWPC did not notice the engineer's yellow background badge, but he was not required to verify that each individual was qualified to enter the RCA. The engineer used the card reader improperly, which allowed him to unintentionally
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" tailgate" the senior engineer through the vital area door to the auxiliary building. Since the engineer's keycard was not coded for access to the Radiologically Controlled Vital Areas, including the Auxiliary Building, it caused a security computer alarm when he used it in the card reader. A nuclear security officer responded as required by procedure. After locating the j
engineer, he confirmed that the senior engineer met the security requirements for an escort, and instructed them on the proper procedure for escorting a person through a Vital Area door.
On July 13, a dosimetry technician reviewing the dosimetry record of the RCA entry noted that the engineer was limited to a radiation exposure of 90 mrem /qtr, which indicated he was not a radiation worker. An issue report was generated to document the issue and to initiate an investigation. The engineer's dosimetry was read. He did not receive any radiation exposure as a result of his RCA entry.
Inspectors found several contributing factors and barriers that failed leading to the improper entry:
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The engineer did not have the GOT Part 2 training required to enter the RCA. Radiation Safety Procedure (RSP) 1-110, " Controlled Area Access Control," states that personnel entering an RCA must have successfully completed GOT Parts I and 2, be an authorized Member of the Public per RSP 1-116, or have completed GOT Part 2 Job Specific Training in accordance with Calvert Cliffs Instruction (CCI) 602, "Calvert Cliffs GOT,"
Section III.G. The engineer did not meet any of the three criteria. The GOT Study Guide states that only personnel who have completed GOT Part 2 and who are working under a valid Special Work Permit shall enter 'an RCA. The GOT Study Guide also i
states that, " Personnel with access to RCAs will have a red background color on their
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picture badge."
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The senior engineer was not a qualified RCA escort. Security Plan Implementing Procedure (SPIP) 1004 states that any person authorized unescorted access into the Vital Areas may act as an escort in their authorized access area. However, the GOT Study i
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The process for issuing thermoluminescent dosimeters (TLDs) and for ensuring that only
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qualified workers signed in on SWPs before RCA entry were not adequate. The engineer obtained his TLD the morning that he entered the RCA.
Though the dosimetry technician recognized that the engineer had completed only GOT Part 1, he was not asked why he needed a TLD or where he was going in the plant, nor did the engineer ask the technician if there were any additional requirements.
Following issuance of the TLD to the engineer, who had a 90 mrem /qtr exposure limit, the dosimetry log at the RCA access point should have been annotated by the dosimetry technician as "no access allowed". However, in this case the dosimetry log was not updated before the engineer signed himself in.
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The engineer believed that he could enter the RCA because he had the appropriate dosimetry and was accompanying someone who was authorized entry to the RCA.
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The senior engineer who was authorized entry to the RCA was a radiation worker who had been on site for approximately four years. She did not discern the significance and
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requirements of the other's yellow background badge. She did not recognize that she was acting as an escort.
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The security officer verified that security escort requirements for a vital area were met, but had no direction to verify RCA escort requirements or to report a potential problem
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to radiation safety personnel. He assumed that the engineer was entering the RCA in accordance with CCI 602. As a result, the improper RCA entry was not discovered by radiation safety personnel until four days later.
Radiation Control and Nuclear Security Sections conducted investigations of the improper entry.
The results were being evaluated by BG&E at the end of the period. In the interim, BG&E took several preliminary corrective actions. TLDs will only be issued to personnel after Dosimetry Section has entered them in the dosimetry record. Dosimetry technicians have been instructed to be more inquisitive before issuing TLDs to personnel with yellow background badges.
Security officers have been instructed to inform radiation safety personnel of any security alarm received in the RCA. An information memorandum was promulgated to all site supervisors on the improper entry. In addition, the Nuclear Training Section is evaluating the effectiveness of GOT, and BG&E intends to issue information cards on RCA entry requirements to non-radiation workers with their access badges. Final corrective actions are pending BG&E's evaluation of i
their internal investigation. BG&E expects that a new Radiological Control Accountability i
Computer System that should be operational in November 1993 will greatly reduce the potential for improper RCA entry.
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Inspectors interviewed the engineers and discussed the eutries with applicable contract supervisors and supervisors of radiation control and nuclear security. Inspectors assessed that the primary causes of the improper entry were: (1) inadequate training on the entry requirements for the RCA, and (2) a failure by BG&E to adequately emphasize the entry requirements. The engineers had a vague recollection of badge color codes, escort requirements, and RCA entry requirements.
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Actual safety consequences of the improper RCA entry were minimal. The engineer did not
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enter any high radiation, contaminated area or airborne radioactivity areas and did not receive
any radiation exposure as a result of his RCA entry.
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Notwithstanding BG&E's corrective actions,10 CFR 19.12 requires that all individuals working in or frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portions of the restricted area; shall be instructed in the health protection problems associated with exposure to such radioactive materials or radiation, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed... The extent of these instructions shall be commensurate with potential radiological health protection problems in the restricted area.
Consequently, entry into the RCA without the requisite training is a violation of 10 CFR 19.12.
Inspectors compared the improper entry to a previous violation of 10 CFR 19.12 documented in NRC Inspection Report 50-317 and 318/93-10. The previous violation also involved improper entries to the RCA, but it was not cited because the criteria for discretion specified in the NRC
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Enforcement Policy was met. The causal factors for the previous violation were different, and BG&E's corrective actions could not reasonably have been expected to prevent this improper RCA entry. Therefore, the current violation also was not cited because the criteria for discretion specified in Section VII.B. of the NRC Enforcement Policy,10 CFR 2, Appendix C, were satisfied.
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Followup of Previous Violations Inspectors reviewed the effectiveness of BG&E's corrective actions for a violation involving two examples of personnel entering posted high radiation areas (HRAs) without a radiation monitoring device as required. The violation (VIO 92-25-01) was documented in a letter from Mr. T. Martin (NRC) to Mr. R. Denton (BG&E), Notice of Violation (Inspection Report Nos.
l 50-317/92-25 and 50-318/92-25), dated January 21, 1993.
Inspectors verified that the corrective actions documented in BG&E's Reply to the Notice of
Violation, dated February 25,1993, were complete. These included enhancement of radiation
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worker training, promulgation of the events to all site personnel, and additional administrative controls over the locked HRA keys issued to operators. There have been no recurrences since
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the violation, despite the challenge of a refueling outage. Inspectors assessed that BG&E's corrective actions were appropriate and that no further NRC review was required.
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l The inspectors toured the onsite emergency response facilitie.; to verify that these facilities were l
in an adequate state of readiness for event response and discussed program implementation with l
applicable personnel. There were no noteworthy findings in this area.
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During routine inspection tours, the inspectors observed implementation of portions of the security plan. Areas observed included access point search equipment operation, condition of l
physical barriers, site access control, security force staffing, and response to system alarms and
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degraded conditions.
These areas of program implementation were determined to be satisfactory.
5.4 Plant Chemistry l
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The inspectors verified that primary and selected secondary water chemistry was maintained within technical specification and procedural limits. In addition, they reviewed secondary water
activity analysis and radiation monitor alarm status to confirm steam generator tube integrity.
l The inspectors also examined analysis trending data to determine if appropriate action was being l
implemented to restore plant chemistry to normal values. There were no unacceptable conditions j
identified.
l 5.5 Fire Protection l
During plant tours, the inspectors assessed plant areas for fire hazards including ignition sources l
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and flammable materials. They also examined fire alarms, extinguishing equipment, emergency lighting, actuating controls, fire fighting equipment, and fire barriers for operability. In
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addition, the inspectors verified that required compensatory measures, such as fire patrols, were l
properly implemented.
l 5.6 Housekeeping i
l The inspectors assessed the control of plant housekeeping in safety related areas. They also l
examined these areas for potential missile hazards such as gas cylinders that could damage safety l
significant equipment. General plant housekeeping during the period was excellent with some noteworthy exceptions. There was a build up of dirt and debris in the intake structure. Also, l
the inspectors noted a significant amount of dirt located in the cooling air intakes for the Unit 2 service water pump motors. BG&E was taking actions to clean these areas as the period i
ended.
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6.0 REVIEW OF WRITTEN REPORTS
The inspector revie'ved LERs and other reports submitted to the NRC to verify that the details j
of the events were clearly reported, including accuracy of the description of cause and adequacy of corrective action. The inspector determined whether further information was required from the licensee, whether generic implications were indicated, and whether the event warranted
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onsite followup. The following LERs were reviewed with respect to the requirements of j
10 CFR 50.73 and the guidance provided in NUREG 1022:
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The inspectors noted that POSRC review of several of the LERs listed below was good. This l
included determination that the initial causal factors were not adequate. Following additional l
causal factor review and documentation, the POSRC found the revised LERs acceptable.
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Unit 1:
93-004 Reactor Trip Due to Turbine Trip Resulting from Inadequate Procedure This event was documented in NRC Inspection Report 50-317 and 318/93-16. The LER reflects an accurate description of the event and causal factors.93-005 TS 3.0.3 Entered, Due to Both Containment Spray Systems Inoperable This event was documented in NRC Inspection Report 50-317 and 318/93-16. The LER was satisfactory.
Unit 2:
93-002 Inadvertent ESF Actuations While Performing Surveillance Testing This event was documented in NRC Inspection Report 50-317 and 318/93-16. The LER reflects an accurate description of the event and causal factors.93-003 Trip on Imw Steam Generator Level Due to Insufficient Feedwater Addition
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This event is documented in NRC Inspection Report 50-317 and 318/93-23. The inspectors reviewed the LER and determined that it accurately portrayed the event and adequately addressed the nuclear safety issues and corrective actions.
Units 1 and 2:
93-003 Dual Unit *-ip Due to Partial I.nss of Offsite Power i
This event is documented in NRC Inspection Report 50-317 and 318/93-16. The LER was i
satisfactory.
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7.0 FOLLOWUP OF PREVIOUS INSPECTION FINDINGS
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l Licensee actions taken in response to open items and findings from previous inspections were reviewed. The inspectors determined if corrective actions were appropriate and thorough and I
previous concerns were resolved. Items were closed where the inspectors determined that
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corrective actions would prevent recurrence. Those items for which additional licensee action was warranted remained open. The following item was reviewed.
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7.1 (Closed) Violation 92-25-01: I!noroner Hich Radiation Area Entries The violation was reviewed and closed as discussed in section 5.1.b.
8.0 MANAGEMENT MEETING I
During this inspection, periodic meetings were held with station management to discuss
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inspection observations and findings. At the close of the inspection period, an exit meeting was held to summarize the conclusions of the inspection. No written material was given to the
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licensee and no proprietary information related to this inspection was identified.
8.1 Preliminary Inspection Findines l
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i A non-cited violation was identified with regard to an improper entry into the Radiologically Controlled Area. The issue is documented in Section 5.1.a. A non-cited violation was identified i
with regard to lack of compliance with maintenance procedures. The issue is documented in l
section 3.2.
8.2 Attendance at Manacement Meetines Conducted by Recion Based Inspectors l
r Inspection Reporting Date Subiect Report No.
Inspector 7/23/1993 Pipe Support 50-317/93-24 S. Chaudhary 50-318/93-24 7/30/1993 Operating 50-317/93-23 L. Briggs Events 50-318/93-23 l
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