IR 05000317/1993027
| ML20057C182 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/14/1993 |
| From: | Joseph Furia, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20057C178 | List: |
| References | |
| 50-317-93-27, 50-318-93-27, NUDOCS 9309280044 | |
| Download: ML20057C182 (5) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-317/93-27 Report No.
50-318/93-27
50-317 Docket No.
10-J_13 t
DPR-53 License No.
DPR-69 Licensee:
Baltimore Gas and Electric Comoany Post Office Box 1475 t
Baltimore. Maryland 21203 Facility Name:
_Calvert Cliffr..sclear Power Plant. Units 1 and 2
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Inspection At:
Lusby. Maryland Inspection Conducted:
September 7-10.1993 O(N
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I Inspectors:
\\,ah
,A 7-/3-93 J. Ffa,3enior Radiation Specialist, date
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Facilities Radiation Protection Section (FRPS),
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Facilities Radiological Safety and Safeguards Branch (FRSSB), Division of Radiation Fafety and Safeguards (DR
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k~N-93 Approved by:
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W. Pasciak, CliIef, FRPS, FRSSB, DRSS date Areas Inspected. Announced inspection of the radiation protection program including:
management organization, assurance of quality, radiation control during normal operations, ALARA, and implementation of the above programs.
Results: ALARA performance during the Spring Unit-2 refueling outage (RF09) was erratic,
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with several major work activities going well over budget for total dose. Continued weakness in outage planning, coupled with a lack of strong ALARA commitment by some
plant staff, supervisory personnel and contractors played a significant part in this weak i
ALARA outage performance.
t 9309280044 930922 PDR ADOCK 05000317 O
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DETAILS 1. Personnel Contacted 1.1 Licensee Personnel D. Adams, Supervisor, Dosimetry
- A. Anuje, Supervisor, Quality Assurance Unit
- P. Chabot, Superintendent, Technical Support W. Coursey, Principle Technician - ALARA
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- S. Hutson, Supervisor, Radiation Control - Operations M. Kratz, Principle Technician - Dosimetry J. Lenhart, Supervisor, Materials Processing
- G. Phair, Assistant General Supervisor, Radiatica Control and Support
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W. Sullivan, Auditor, Quality Assurance Unit
- B. Watson, General Supervisor - Radiation Safety
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- R. Wyvill, Supervisor, Radiatico Control - ALARA 1.2 NRC Personnel i
K. Lathrop, Resident Inspector F. Lyon, Resident Inspector
- P. Wilson, Senict Resident Inspector
- Denotes those present at the exit interview on September 10, 1993.
2. Radiation Safety l
Since the last inspection in this area, the licensee has begun a limited reorganize. tion of
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the Radiation Safety Depanment, including the creation of a second Assistant General i
Supervisor's position, a reduction in the number of personnel directly reporting to the-General Supervisor - Radiation Safety (GSRS), and the combining of the decontamination -
and scheduling activities. At the time of this inspection not all the newly created I
positions, especially the Assistant General Supervisor's position, had been filled. The impact of this new organizational structure will be evaluated during a future inspection in this area.
2.1 ALAR A The licensee conducted its refueling N * 3 9 (RF09) for Unit 2 during the late winter -
and spring of 1993. Significant work.1 % included the refuel activities, replacement of one reactor coolant pump motor, won e e shutdown heat exchangers, cleaning of the containment air coolers, and the norma work associated with reactor disassembly, l
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refueling and reactor reassembly. Prior to the start of the outage, several outage performance goals for radiological safety were established. These goal.s and the final results are listed below:
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Outage Performance Indicator Goal Actual
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Total Outage Site Dose
<225 Rem 313 Rem Individual Dose
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J Preventable Personnel Contaminations
< 73
Outage Duration
< 105 days 114 days
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The most radiologically significant emergent work encountered during the outage was the
leakage of the In-Core Instrumentation (ICI) flanges, which, in conjunction with a known rusting problem with the Containment Air Coolers, led to extensive contamination of the containment, necessitating additional respiratory protection and protective clothing
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requirements for many work activities, and the additional dose expended dming clean-up of the ICI flanges. The licensee calculated that %.1 Rem of additional site dose was directly attributable to the ICI problem, including: 20.1 Rem additional dose during
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cleaning of the Containment Air Coolers; 15.4 Rem of additional dose for ICI flange
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removal and cleaning; 6.1 Rem of additional dose for Radiation Safety personnel to cover work in the containment; and 2.5 Rem of additional dose for replacing reactor head j
insulation damaged by the boron from the ICI leak.
In addition to the ICI flange leak, emergent work during the outage outside of the ICI
problem added an additional 3.8 Rem, including 1.3 Rem for additional weld repairs to the Refueling Water Tank and 2.5 Rem for reactor vessel level monitoring system weld a
repairs.
Problems encountered during the outage led to an additional 27.0 Rem, including: 11.1 Re-Sr additional dose during the refueling path (due at least partly to t
the higher dose rat-
'-d by the ICI flanges; 8.3 Rem due to installation problems
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with the nozzle das e he need to drill out 104 Inconel 600 type steam generator tube plugs; 4.3 Rem for the replacement of additional containment insulation; and 3.3 Rem additional dose during the installation of the Shutdown Cooling Heat Exchangers spacers.
Another 11.0 rem of additional dose was attributed to " overly aggressive refueling path i
goal."
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The licensee's analysis of the refueling outage ALARA performance was contained in its
"1993 ALARA Outage Report." The timely issuance of this report is a significant
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improvement relative to past outages, where these types of reports either were not done or were issued 9 to 12 months after the close of the outage, often after the start of the
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next refueling outage at the site. This report indicates that the ALARA and Radiation i
Safety staff attributes significant portions of the additional dose, outside of the emergent work created by the ICI flanges, as project control problems. An excessive number of
workers in the containment at certain jobs (which was observed by the inspector during
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1 carlier inspections), a lack of appropriate ALARA perspective on the part of some work
control personnel, and internal scheduling problems within the Radiation Safety i
Department were identified in the report as significant contributors.
Inspector review of outage performance revealed that a large number of work order l
packages were not received by the ALARA group for review and issuance of Special Work Permits and ALARA reviews until after January 1,1993, which left only 6-7 weeks prior to the outage for this important work. Additional problems identified with
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certain jobs included significantly higher dose rates than anticipated at certain job sites (insulation replacement and #21 A Reactor Coolant Pump), scope of work not properly identified (insulation replacement), and inexperienced job managers (Containment Air Coolers). In the case of the Containment Air Cooler work, inexperienced system engineers were assigned project management for thejob, large work crews were utilized,
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often with a significant number of workers staying in the Containment with little or
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nothing to do, and planning for thejob, especially the mechanics of the cleaning activity, being poorly done. These problems are in many ways repetitive, in that similar problems were encountered during the 1992 Unit I refueling outage (RF10), and yet were not properly addressed in time for this outage.
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The licensee has begun to address some of the identified weaknesses, most notably by the creation of an ALARA Committee, and the placement of a Principal ALARA Technician into the Outage Management Team in preparation for the Spring 1994 Unit I refueling outage (RFl1). Discussions with ALARA personnel, together with a limited review of planning for the 1994 outage indicated that while the placement of the technician into the outage management organization was an improvement, much greater
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improvements in ALARA interfacing with outage management, and more timely submittal of work packages for ALARA review is still needed.
2.2 Radioloeical Operations
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As part of this inspection, several tours of the Radiologically Controlled Area (RCA)
were made. In general, plant radiological housekeeping was determined to be very good, with total contaminated areas less than 8000 square feet. In addition, the on-going plant restoration project had recently been completed in the radwaste processing area on the 45' elevation of the Auxiliary Building, significantly improving working conditions in this area. Improvements included the replacement of the hydraulic cask trolley with an
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electrical system, decontamination and surface sealing of the pit area, together with the installation of a remote sampling system for resin transfer.
During this inspection, the licensee shipped a Chem-Nuclear Systems, Inc. 3-55 Type B shipping cask, loaded with irradiated hardware (4610 Curies), to the Barnwell IAw-Level Waste Disposal Site. This shipment, together with a smaller shipment scheduled forlater in September, represents the conclusion of a long term fuel pool clean-up operation. The
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shipment and its associated documentation was reviewed by the inspector and determined to be in compliance with the applicable provisions of Titles 10 and 49 of the Code of Federal Regulations.
2.3 Assurance of Ouality As part of this inspection, a review of recently completed audits and surveillances of radiological safety activities was conducted. Two surveillances related to radiological activities had been conducted so far in 1993, one each in the areas of survey instrument calibration (Surveillance S-93-05) and radwaste shipping (Surveillance S-93-03). No I
additional surveillances were scheduled at the time of this inspection. In addition to the surveillances, two audits of radiological safety activities were completed in 1993, Audit 93-04, " Radiological Protection" and Audit 93-10, " Radiological Effluent Technical j
Specifications." The first audit was conducted in part during the Unit 2 refueling outage (RF09), while the second audit included a review of the Process Control Program (PCP)
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for radwaste processing, as required by plant Technical Specifications. Each audit was
conducted by qualified Quality Audit Unit personnel, with the second audit team
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including an outside technical consultant.
Both audits were determined to be of appropriate depth and technical scope. Neither audit identified any safety significant
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issues.
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3. Exit Interview The inspector met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on September 10,1993. The inspector summarized the purpose, scope and findings of the inspection. The licensee acknowledged the findings of the inspection.
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