IR 05000317/1997061
| ML20217R349 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/18/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20217R343 | List: |
| References | |
| 50-317-97-61-EC, 50-318-97-61, NUDOCS 9709050083 | |
| Download: ML20217R349 (50) | |
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U.S. NUCLEAR REGULATORY COMMISSION Meeting No. 97 61
REGION I
Docket Nos:
50 317, 50 318 License Nos:
DPR 53, DPR 69 Predecisional Enforcement Conference (PEC)
Report Nos.
50 317,50 318/97 61 Licensee:
Baltimore Gas and Electric Company (BGE)
Facility:
Calvert Cliffs Nurtear Power Plant, Units 1 & 2 PEC Date:
Thursday, June 12,1997 Location:
Public Meeting Room, U.S. Nuclear Regulatory Commicslon, Region I, King of Prussia, Pennsylvania Prepared by:
T. Mostak, Project Engineer Approved by:
Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects Summarv: An open Predecisional Enforcement Conference was held at the NRC Region i Office in King of Prussia, Pennsylvania on June 12,1997, to discuss apparent violations identified during NRC inspections conducted between March 2,1997 and April 24,1997.
The inspections identified apparent violations regarding a series of problems occurring during fuel handling operations and the control of high radiation area access including the failure to effectively control diving activities in the Unit 2 spent fuel storage pool. The specific causes and broader implications of each apparent violation were discussed.
Licensee correctivs actions plc.ined or completed since the inspections were outlined. No enforcement decisions were reached at the conference.
Attachments:
1. List of Attendees 2. Licensee Viewgraphs 9709050083 970810 PDR ADOCK 05000317 O
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DIIAILE 1.0 Conference Attendees A list of persons attending the predecision61 enforcement conference (PEC) is included as Attachment 1 to this report.
2.0 Conference Summary Detween the period March 2,1997 through April 24,1997, several apparent violations of NRC requirements were detailed in NRC Inspection Report 50 318/97 02. The inspection identified apparent violations regarding a series of problems occurring during fuel handling operations and the control of high radiation area access including the failure to effectively control diving activities in the Unit 2 spent fuel storage pool. A PEC was conducted on June 12,1997 to discuss these apparent violations, the licensee's assessment of the causes of these apparent violations, and the corrective actions planned or completed by the licensee. The PEC was open for public observation.
NRC management opened the PEC by identifying the purpose of the conference to discuss the significance, root causes, and corrective actions for the apparent violations. Licensee representatives provided their assessment and response on the issues. A copy of the licensee's presentation is provided as Attachment 2 to this report. Throughout the conference, the licensee responded to questions and requests for clarifications from the NRC staff members.
3.0 Closing At the end of the PEC, the NRC summarized their understanding of the causes and responses presented by the licensee and closed the meeting. No enforcement decisions were reached during the conference.
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ATTACHMENT 1 Predeelslonel Enforcement Conference Calvert Cliffs Nuclear Power Plant June 12,1997 List of Attendees:
Saltimore Gas and Electric Comoany C. Cruse, Vice President Nuclear Energy P. Katz, Plant General Manager T, Pritchett, Director, Regulatory Matters T. Syndor, General Supervisor, Plant Engineering
- K. Cellers, Superintendent, Nuclear Maintenance K. Neitmann, Superintendent, Nuclear Operations B. Watson, General Supervisor, Radiation Safety NBC H. Miller, Regional Administrator, Region I L. Nicholson, Acting Deputy Director, Division of Reactor Projects (DRP), Region 1 J. Furia, Acting Chief, Radiation Safety Branch, Division of Reactor Safety (DRS)
L. Doerflein, Chief, Projects Branch 1, DRP R. Nimitz, Senior Radiation Specialist, DRS S. Stewart, Senior Resident Inspector, Calvert Cliffs, DRP, Region 1
- A. Dromerick, Project Manager, Project Directorate I 1, Office of Nuclear Reactor -
Regulation (NRR)
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ATTACHMERT 2 Predecisional Enforcement Conference Concerning Fuel Handling Operations and High Radiation Area Access Presented by Baltimore Gas and Electric at NRC Region IOffice, King ofPrussia, PA Jime 12,1997
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Management Summary hitroduction
- Events c.uring this outage have highlighted wea alesses in some of our processes
- We are not satisfied with our performance; it clearly does not meet our standards
- We are correcting these weaknesses
- A number of strong management actions were taken
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Presentation Outline I
I ControlofHRAAccess CcitoldFuelHandling i
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I EALAccess Diver FuelHandirgEqu~pTed OpertionofEquirnerit i
instructions VeryHiahRafetion
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SFPVentilation LostissueReports toDiver
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SurvillanceTest
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Afsnment Surveys
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Fie n ffghRadiationArea EntryEvents Scaffold 21RCPBay
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ControlofHigh Radiation Area Access Bruce A. Watson, CHP General Supervisor-Radiation Safety
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Control of High Radiation Area Access Issues to be Discussed
- Unit 2 Spent Fuel Pool Dive April 3
- High Radiation Area Lock February 16 Control for the Emergency Airlock
- RCP Bay Entry Without TLD/EPD May 1
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- Scaffold Constructed into a May 4
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Spent Fuel Pool Dive
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Event Summary (April 3)
Diver in spent fuel pool replacing transfer carriage proximity switch magnet
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Diver unknowingly left the approved diving area to inspect a cable Diver exceeded the 100 mrem whole body planned exposure Radiation detection equipment prevented significant exposure
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l Spent Fuel Pool Dive i.
Event Summary Immediate Actions Diver was instructed to leave the pool Dive Team debrief conducted Human Performance Evaluation initiated
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Diver Dose Body Location TLD Measurement (REM)
Wholebody - Chest 0.076 Wholebody - Back 0.045 Head 0.137 Right Thigh 0.034 Left Thigh 0.029 Right Wrist 0.439 Left Wrist 0.122 Right Ankle 0.021 Left Ankle 0.018 Right Elbow (Calculated)
0.270 Right Knuckle (Calculated)
0.885
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Dive Details Dive Preparation
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Spent Fuel Pool
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Diver and RO-7 Probe
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TLD and SAIC Locations (100 mrem;
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850 mrem /hr)
Diver Location, Movements, and Recovery
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Summary of Causal Analysis Cause 1
- Failure to follow established guidelines resulted in loss of positive control of the diver Cause 2
- Unclear overall control and leadership of the
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dive evolution Cause 3
- Communication methods were unclear; did not
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Safety Significance Spent Fuel located at the Rack Coordinate #63 and
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as " Hot Particles", which could have contributed to the Diver's dose (10 CFR 20.1501), 3ased on; t
- Diver's experience and instructions l
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- Diver's survey technique using the RO-7
- Diver's location was consistent with Post Job Debrief (s)
- Post event comprehensive radiation survey
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Safety Significance Radiation field entered near #68 Highest postulated radiation field the Diver may have encountered near Rack Coordinate #68:
- Whole body 90 Rem /h (right forearm)
- Extremity 310 Rem /h (right knuckle)
More likely dose rate ranges (based on actual measurements, diver time estimates, interviews,
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and mockups):
- Whole body 45-90 Rem /h
- Extremity 155-310 Rem /h
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Actual Safety Significance Diver did not receive a significant l
dose less than 10% of the annual Regulatory Limits The diver did not enter a Very High Radiation Area
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Rad', logical Controlled Area Dive Summary of Corrective Actions i
MK 1-113, " Radiological Controlled Area Dive
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Operations," has been changed
- Defines dives as infrequent maintenance evolution
- Defines leadership responsibilities
- Defines physical barriers Job Coverage Standard-018 has been formalized into a Radiation Safety Procedure
- Controls for Very High Radiation Areas l
- Enhanced Dosimetry
- Positive Diver Controls
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High Radiation Area Lock Control l
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l ControlofHRAAccess ControlofFuelHandrog f
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FuelHandlingEq'ipnent Operationo!E4 pment
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Instructions VeryfighRadiation
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TransferCarriage SFPVentilation SFPVentilation
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Afgnment SurvellaxeTest
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HighRadationArea EntryEveMa Scaffold 21RCPBay
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High Radiation Area Lock Control for the Emergency Airlock (February 16)
Background HRA left unlocked (Containment)
- During containment entry, EAL HRA lock left on
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floor ofvestibule
- Security.ock in place on vestibule door Lock reinstalled on tae EAL handwheels and Issue Report (IR) written
- Prior to subsequent containment entry (2/18), RS personnel identified.ock on EAL handwheels as a potential safety issue for egress; Wrote IR The IR's regarding the EAL issues were lost
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High Radiation Area Lock Control for the Emergency Airlock Corrective Actions Clarified expectations on EAL HRA loc 1 p_acement Training was completed for Appropriate Radiation Safety personnel (in anticipation ofIssue Reports
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Issue Reports were rewritten
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l High Radiation Area Lock Control for l
I the Emergency Airlock Preventive Actions Lock placed on vestibule door to e_iminate personnel safety issue l
Revised Containment Access ?rocedure cheeldist to place the EAL HRA lock on the vestibule door j
Training on tae Corrective Action Process Radiation Safety Supervision reviews precursor l
information at weekly Radiation Safety staff l
meetings
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High Radiation Area Entry Events I
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ControlofHRAAccess ControlofFuelHandfog I
EALAccess Diver
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FutlHandlingEquipment OperationofEquipment lastructions VeryHghRadiation LostissueReports to D.iver AreaAccess
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MaterialCondition
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Afgnment SurveilanceTest Surveys
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RCP Bay Entry Without TLD or EPD Background Electrician wor 1ed for 1 1/2 aours in the 21 Reactor Coolant Pump (RCP) Bay without a TLD or EPD
- Left dosimetry in the Rac iological Controlled Area dress out area Another BGE employee discovered dosimetry and reported to Radiation Safety 21 RCP Bay was a Posted. High Rad Area Work Area Dose Rates were 4-6 mR/h and RS
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RCP Bay Entry Without TLD or EPD
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Immediate Corrective Actions P: ant General Manager stooped work unti interim corrective actions complete Positive verification ofRadiological Controlled Area entry requirements incorporated into Rac.iation Safety Procec ure Plant Genera Manager communicated expectations to site personnel n
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Scaffold Constructed into a High Radiation Area l
Background
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Two workers were building scaffold in the l
Auxi:Liary Building l
Radiation Safety Tecanician did not perform surveys during scaffold construction
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(approximately 24 feet) was being constructec l
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300 mR/h (High Radiation Area) in the overhead l
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Scaffold Constructed into a High Radiation Area Immediate Actions Plant General Manage: stopped all non-refueling work in the Radiological Controlled Area Conducted surveys; interviewec personnel Corrective Actions
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Changec EPD's to alarm at 80 mR/a or less for non-High Radiation Area wor t
Conducted training review Preventive Actions GS-RS implemented controls to restart work; briefed Raciation Safety personne.
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.f Summary Actions to Prevent Recurrence Radiation Control Procedures Self-assessments (top to bottom review)
- NRC Requirements
- Bases documents / Industry Events
- Worker knowledge and awareness Eliminate Job Coverage Standards and Guidelines and formalize into procedures Evaluate assigned procedure usage level Benchmarking
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Summary of Preventive Actions Radiation Safety Technician Training Job, Coverage & Field Requirements Instrumentation & Technology Industry & Plant Events Supervisory and Management Oversight i
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Control ofFuelHandling Tom Sydnor General Supervisor-Plant Engineering i
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Control of Fuel Handling l
Issues to be Discussed
- SFP Ventilation Surveillance Test
- Use of drawings for troubleshooting Fuel Transfer Carriage Interference
- Material condition of fuel handling equipment
- 3000 Pound Overload Protection
- SFP Ventilation alignment
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SFP Ventilation Surveillance Test
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ControlofHRAAccess ControlofFuelHandfrg i
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! uelHardingEquipment OperationofEgia ise
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F r
x Instructions VeryMghRadiation LostissueReports to D's AreaAccess
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SFP Ventilation Surveillance Test (January 10)
Background During review of a spent fuel pool ventilation positive pressure issue, identifiec a : failure to perform a STP requirement
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Full test had not been run since 9/94; due 3/96
- Partial test run 7/95 did not verify negative pressure; did verify exhaust fan operability,
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HEPA aank operability, and air distribution Operator logs indicate negative pressure test was
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TS Violation was discussed in LER 317-97-001
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SFP Ventilation Surveillance Test Immediate Actions
- Ful: STP was performed on January 24,1997; verified tae operability of the system
- Information concerning the missed STP was inc uded in LER Preventive Actions
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- Review of all current STP's verified no additional STP's were missec.
Safety Significance
- Low; System was confirmed to be fully operable
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Transfer Carriage Interference i
I ControlofHRAAccess ControlofFuelHandh i
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EALAccess Diver
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Instructions VeryFEghRadiation
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Mater'alGnddon IpW S m en M n SMenMon LostissueReports toDiver AreaAccess
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Transfer Carriage Interference (March 28)
Background Bent proximity switch magnet interfered with the upender pivot bracket Could not send the fuel transfer carriage fully into
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the SFP upender Preventec full closure of tae fuel transfer tube gate i
va_ve Vic eo was used concurrent y with drawings l
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Transfer Carriage Interference l
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Immediate Actions L
Sto;pec. al: core alterations Corrective Actions Developed interim action plan in case gate valve needec to be shut
- Drawings were in use witain 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> l
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Preventive Actions System Engineering undertook a review of fuel i
handling equiament Safety Significance Initially mec ium; Low probability ofinventory loss
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Material Condition of Fuel Handling Equipment
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ControlofHRAAccess ControlofFuelHandling i
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EALAccess Diver FuelHuding5iuipmert OperationofEquipment
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TasfuCasge SHeMMon SMeMMn LostIssueReports toDiver AreaAccess D
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l Material Condition of Fuel Handling Equipment l
Background
- There were a number of fuel handling equipment de ~1ciencies and aroblems during
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c efueling activities l
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Material Condition of Fuel Handling Equipment Corrective Actions Reviewing Preventive Maintenance Program
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Considering accelerating previously approved control f
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Raise performance standards for Fuel Handling Equipment l
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Preventive Actions Added fuel handling equipment to Maintenance Rule
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Reviewing other non-scoped systems for applicability Upgrades in approach to maintenance being pursued, l
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Safety Significance: Low
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3000 Pound Overload i
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ControlofHRAAccess ControlofFuelHandling i
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EALAccess Diver FuelHandlingEquipmat OperationofEquipment
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lastructions
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3000 Pound Overload Protection (April 1)
Background Based on internal review, the Refueling Machine overload limit switch design determined to not meet Tech Specs (Self-Identified)
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The overload protection circuit was
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bypassed during 6 inches of vertical travel The bypassed region was afterfuel assemblies withdrawn from the core Original design of Refueling Machine
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3000 Pound Overload Protection Immediate Actions Prohibited fuel movements
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Corrective Actions Reviewed design against the Current Licensing Basis
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Modified 3000 pound bypass circuitry to comply with TS
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Preventive Actions l
Looking at alternative solutions such as different
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modification or TS change Communicated the issue to Indust 1y
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- Several other plants have the same problem Safety Significance Low; bundle clear of the core; in hoist box
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I EALAccess Diver FuelHandlingEgipret OpendiodidEquipment Mk~
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Instructions Veryf5ghRadiation LostissueReports toDiver AreaAccess
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TransferCarriage SFPVentilation
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I SFP Ventilation Alignment l
(April 23)
I Background
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Performed pre-requisites to move fuel
- Fuel Handling Operator powered up machine
- Control Room Operator confirmed ready to move fuel
- Skipped OI-25 step to ensure charcoal filters operating Fuel Handling Operator thought Control Room
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confirmation included filters aligned Moved cummy fuel aundle; then moved fuel Self-identified by operators during shift turnover (panelwalkdown)
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SFP Ventilation Alignment l
Immediate Actions Site Management stopped all refueling activities
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Assigned team to conduct overall root cause analysis for
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SFP misalignments, refueling equipment problems, and control of dive activities Corrective Actions Site wide awareness training / safety break
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Verified current plant configuration to ensure fuel safety l
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- Containment closure lineups, SFP ventilation, SFP l
cooling, and shutdown cooling
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Developed action plan for resuming refueling activities.
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- PGM gave specific assignment for review at GS and Superintendent level
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SFP Ventilation Alignment Corrective Actions
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Made technical preparations for safe reload of fuel
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- Reviewed to ensure adequacy of operator training,
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. operations procedures, engineering, and maintenance
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necessary for refueling
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Plant Management Review reviewed actions and made
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recommendations to PGM and VP to resume refueling Preventive Actions Longer term actions from root cause analysis are being
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implemented Safety Significance Low; Abnormal Operating Procedure covers accident scenario
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Summary Control of Fuel Handling
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Command and Control ofRefueling Operations Overall Ownership of Refueling Activities
- Plant Engineering provic es tec:nlical support to ensure equipment performs as designec.
- Communications
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Summary Control of Fuel Handling (Preventive Actions)
Emphasized that Operations is the Program Owner for refueling activities Identified Refueling as an infrequent evolution requiring special controls
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