IR 05000317/1998005
| ML20248K059 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/02/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20248K056 | List: |
| References | |
| 50-317-98-05, 50-317-98-5, 50-318-98-05, 50-318-98-5, NUDOCS 9806090406 | |
| Download: ML20248K059 (17) | |
Text
. _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ - _ - _ - _ - _ - _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ - _ - _ _ _ _ - - _ _ - _ . _ .- _ _ _ - _ ___ __ _ .
.
.
U.S. NUCLEAR REGULATORY COMMISSION j
REGION I
Docket Nos: 50-317;50-318 ;
'
License Nos: DPR-53; DPR-69 Report Nos: 50-317/98-05;50-318/98-05 Licensee: Baltimore Gas and Electric Company Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, Maryland Dates: April 20-24, May 11-14,1998, and May 19-20,1998 Inspectors: R. L. Nimitz, CHP, Senior Radiation Specialist J. Noggle, Senior Radiation Specialist Approved by: John R. White, Chief Radiation Safety Branch Division of Reactor Safety 9906090406 990602 PDR ADOCK 05000317 G PDR
_____ _____-___ _ -
F 1
.
s
.
EXECUTIVE SUMMARY l
Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection Report Nos. 50-317/98-05and 50-318/98-05 This inspection was a special onsite safety inspection conducted by NRC Region I inspectors during the period April 20-24, May 11-15, and May 19-20,1998, at the Calvert Cliffs Nuclear Power Station. The princinal focus of the inspection, was the circumstances, licensee evaluations, and corrective actions associated with high radiation area radiological controls problems experienced during work in the Unit 1 reactor vessel r
annulus on April 9,1998. Also reviewed were radiological controls for the Unit 1 outage including, external and internal exposure controls, radioactive material and contamination controls, and efforts to reduce occupational radiation exposure to as low as reasonably achievabl E{ ant Sucoort
- BG&E implemented corrective actions and initiatives for previous radiological controls problems experienced during the 1997 Unit 2 refueling outage. However, implementation of these corrective actions and initiatives was not fully successfu Radiological control deficiencies, similar to previously identified programmatic deficiencies (observed during the 1997 Unit 2 outage), occurred at the onset of the 1998 Unit 1 outage, resulting in several apparent violations of radiation protection procedures and unplanned exposure to an individua BG&E's radiological controls for replacement of nuclear instrumentation detectors in the Unit 1 reactor annulus on April 9,1998, were ineffective. Eight examples of failure to implement radiation protection procedures for high radiation area work as required by Technical Specification 6.4. were identifie BG&E implemented a number of corrective actions and initiatives following the April 9,1998, unplanned worker exposure event including enhanced review and oversight of work activities by radiation protection supervisory personnel. Planning and preparation for work activities reviewed was comprehensive. BG&E provided generally effective control of airborne radioactivity and no significant internal exposures were identified as of the end of the inspectio BG&E was effectively implementing its commitments to the NRC as documented in NRC CAL No. 1-98-006, dated April 29,199 ii
_ _ _ - _ _ - _ _ _ _ _ _ _ _ - _
i i
l
l
.
Report Details Plant Suncort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Plannina. Preparation and Corrective Actions l
l Scope The inspectors selectively reviewed BG&E's planning and preparation for the Unit 1 l
refueling outage. In addition, the inspectors selectively reviewed BG&E's corrective action taken as a result of radiological controls problems that occurred during the 1997 Unit 2 outage. The previous radiological controls problems were the subject of NRC Escalated Enforcement Actions (Reference NRC Inspection Report No ; 318/97-02 and 50-317; 318/98-03). The inspector met with cognizant BG&E personnel, reviewed applicable documentation, and reviewed in-field i nplementation of corrective action Observations and Findinas BG&E prepared a Calvert Cliffs Unit 1 1998 ALARA Preoutage Report. The report, dated March 8,1998, described and summarized all major outage work activities, including the ten year reactor vessel inservice inspection work. The report provided a good summary of planned work activities including contingency work, expected radiation exposure, expected person-hours, and ALARA initiatives. The report also summarized previous radiological problems and summarized efforts to improve performance and preclude problems. The report received wide distributio BG&E prepared a 1998 Radiation Control Outage Plan, dated March 4,1998.The plan identified major work activities and management expectations relative to radiological controls personnel performance during the outage. The plan also provided expectations regarding radiological surveys, adherence to procedures, and specific expectations regarding control of high radiation area work. The plan was proviaed to all radiological controls personnel for information and implementatio As a result of several radiation protection program deficiencies experienced during the 1997 Unit 2, BG&E implemented a Radiation Protection Improvement Plan. The plan provided for numerous initiatives to improve radiological controls, including those for refueling outages. The plan provided for improvement of performance in radiation protection with respect to 1) improvement in management oversight and j communications,2) integration of radiation protection into work programs, ;
3) improvement of site personnel radiation protection knowledge,4) improvement m '
radiation protection assessments, and 5) improvement of radiation protection I program processes and procedure ;
l As part of this plan, BG&E reviewed all planned radiological work activities for the l 1998 Unit 1 outage and identified work considered "high risk" radiological wor l Such work involved the potential for significant radiological controls problems and was specifically highlighted during outage planning activities. Planning and
,
__. _ _ , _ - _ _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ . - - _ _ . _ - - _ - _ . . _ - _ - _
.
.
preparation for such work was to include pre-work planning as well as extensiv integrated pre-job worker briefings in order to preclude radiological controls problems. BG&E also enhanced radiation protection procedures for work coverage and control.-
Notwithstanding the above, BG&E's implementation of corrective actions and initiatives were not fully successful in that on April 9,1998, BG&E again experienced significant radiological controls performance problems during worker entries into the Unit 1 reactor vessel annulus. During the entries, several workers were not provided with the special alarming dosimetry that was required by the applicable Specific Work Permit tc monitor and control entry into high radiation areas. One worker roceived unplanned radiation exposure and exceeded the licensee's administrative exposure limit as specified by the applicable Special Specific Work Permit (SWP) due to deficient conduct of radiological control and monitoring activities. These matters are discussed in Section R1.2 of this repor Conclusion BG&E implemented corrective actions and initiatives for previous radiological controls problems experienced during the 1997 Unit 2 refueling outage. However, implementation of these corrective act%ns and initiatives was not fully successfu Radiological control deficiencies, similar to previously identified programmatic deficiencies (observed during the 1997 Unit 2 outage), occurred at the onset of the 1998 Unit 1 outage, resulting in several apparent violations of radiation protection procedures and unplanned exposure to an individua R1.2 Radiological Controls for Excore Nuclear instrumentation Work insoection Scoos (92904. 83750)
The inspectors reviewed the circumstances, licensee evaluations, and corrective actions associated with radiological controls problems encountered during work in I
the Unit 1 reactor vsssel annulus on April 9,1998. During the work, multiple workers entered into the Unit 1 reactor cavity and reactor annulus without required alarming dosimetry devices. Further, a worker sustained an unplanned radiation exposure during entry into the annulus. The review included applicable documentation and discussions with cognizant personnel. The inspector reviewed information provided by the Significant incident Finding Team (SIFT) established by the licensee to review the event . Observations and Findmas On April 9,1998, as part of its predictive maintenance program, BG&E initiated work to replace three Unit 1 reactor excore power range nuclear instrumentation (NI) detectors. The detectors are contained within instrument wells (tubes) located
,
within the reactor annulus, approximately 15 feet below the 44 foot elevation of the L reactor cavity. The replacement of the detectors involved multiple personnel entries into the reactor vessel annulus to remove insulation and prepare the detectors for
'
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
3 removal and replacement. The annulus area is normally a locked high radiation area (i.e., radiation dose rates exceeding 1,000 mR/hr) and personnel entry requires
- implementation of specific radiological access contiois and worker radiological coverage. Radiation dose rates ranged frnm 2,000 mR/hr to 6,000 mR/hr. The work activity was pre-identified by the licensee as a "high risk" radiological work activity and was the first scheduled "high risk" radiological activity for the Unit 1 outage. Activities identified by BG&E as "high risk" activities involve the potential for significant radiological controls problems and were the subject of enhanced planning and preparation, in preparation for entry into the reactor annulus, the licensee removed the annulus shielding blocks and plates, located on the 44 foot elevation of the reactor cavity, on the day shift of April 9,1998. No radiological problems were encountered l during this work activity. Preliminary radiation surveys were performed at that time on the 44 foot elevation of the reactor cavity and partially in the annulus to
'
- characterize radiological condition The initial radiological controls pre-job briefing activities to support entry of a work crew into the annulus was initiated in the early evening of April 8,1998. However, I due to less than optimum briefing facilities and lack of attendance by all affected personnel, a second briefing was held later that evening. Workers were briefed on the radiological conditions based on the preliminary radiation survey dat Radiological survey im'ormation, for all areas to be entered by workers in the reactor annulus, was not ava lable. While l&C Supervisors attended the briefing, no Radiation Protection 9epartment Supervisors were present for any of the briefing The radiological controls coverage of the task was provided by two contractor senior radiation protection technicians, one of which had previously provided coverage for similar work. During preparation for the entry on the late evening of April 8 and early morning of April 9,1998, the technicians encountered problems gathering all dosimetry devices that were required for the work activity per the S W In preparation for the entry into the annulus, the lead licensee radiation protection technician (zone technician), responsible for oversight of work activities on the containment refueling floor, performed a survey of work areas within the annulus shortly before the entry by workers. This survey data was not documented and reviewed by radiation protection supervision or the workers prior to entering the locked high radiation area. Workers and contractor radiation protection personnel only received verbal briefings regarding the dose rates as they were preparing for the work. The zone technician also informed the workers and contractor technicians of the area stay time. The zone technician had performed a mental calculation and estimated the stay time in the annulus area of 9 minutes. This calculation was based on the time to accumulate 600 millirem (the SWP dose limit) :
in a 4,000 mR/hr radiation field. The zone technician subsequently left containment i and did not provide any further oversight of on-going radiological control activities i including oversight of the assigned contractor radiation protection technician ;
!
,
_ _ _ . _ _ . _ _ _ _ _
...
4 As part of the radiological controls for the task, the two coverage technicians used the stay time to control the exposure of the workers in the reactor annulus. The .
l coverage technicians believed the stay time calculation, performed by the zone technician, was the time to sustain an exposure of 510 millirem in a 4,000 mR/hr radiation field (lower annulus ledge). The 510 millirem value was the alarm setpoint specified on the SWP for the alarming dosimeters required by the SWP and provided a dose margin to preclude workers from exceeding their SWP dose limit
- (600 millirem). The correct stay time, to sustain an exposure of 510 millirem, was 7.6 minutes rather than 9 minute (Note: As discussed later, the alarming dosimeters were not provided to the workers.)
Technical Specification 6.4, Procedures, (Amendment No. 216) requires in Section 6.4.1 that written procedures shall be established, implemented and maintained covering, among other matters the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 197 Regulatory Guide 1.33, Revision 2, recommends in Appendix A, Section e., that radiction protection procedures be established including procedures for access control, radiation surveys, radiation permit system, and personnel monitorin BG&E Radiation Protection Procedure 1-132, Revision 1, provides requirements and responsibilities for radiation safety personnel to implement radiological coverag Section 6.1.F of that procedure required radiation safety personnel to perform SWP requirements, i.e., assure that all SWP requirements are met and that radiological conditions and worker dose are monitored. The special SWP (SWP No.1312, dated March 31,1998), stated that work coverage radiation safety technicians shall determine stay times for all workers entering high radiation areas based on the most current survey data.
'
The workers only entered the annulus for short periods of time and did not sustain radiation exposures in excess of the SWP dose limit or the alarming dosimeter setpoint. Notwithstanding, the failure of the coverage technicians to properly determine stay time in the high radiation area is an apparent violation of radiation
- protection procedures required by Technical Specification 6.4. (eel 50-317/98-05-01A)
BG&E Radiation Protection Procedure RSP 1-132, Revision 1, required in Section 6.1.F. that radiation safety personnel perform SWP requirements, i.e, assure that all SWP requirements are met and that radiological conditions and worker dose are monitored. The Special Specific Work Permit (SWP) (SWP No.1312, dated
. March 31,1998), required that workers be provided with special dosimetry and that alarming dosimetry be used by workers wearing special dosimetry. Personnel were
- to utilize ALNORS (a type of alarming dosimeter) if SAIC dosimetry (another type of alarming dosimeter) were not used. Further, the SWP required that sacrificial dosimetry (a 0-1.5 R direct reading dosimeter) be worn by personnel wearing special dosimetry; and that the sacrificial dosimetry be positioned on the whole body at the location where the highest dose rate field is expected. Neither the ALNORS or the
- use of sacrificial dosimetry was discussed at the pre-job brief. Only use of SAIC dosimetry was discusse _ _ _ _ - _ _ - - _ - _ _ _ - _ _ _ _ .J
.
.
Although ALNOR alarming dosimeters were apparently prepared for use by the zone technician, the dosimeters were not provided to the workers for use during their entry into the reactor cavity and annulus. Further, according to the SIFT team findings, sacrificial dosimetry was not used as prescribed by the SW Between about 1:00 a.m. and 5:G0 a.m. on April 9,1998, six workers entered the Unit 1 reactor cavity under specific SWP No.1312, wore special dosimetry but, 1) were not provided with SAIC or ALNOR alarming dosimeters; and 2) did not wear sacrificial dosimetry as prescribed by the Special SWP. Four of the workers made entries into the reactor annulus for short periods of time.
l The failure to provide prescribed dosimetry to workers is an apparent violation of radiation protection procedures required by Technical Specification (eel 50-317/98-05-01B)
The workers completed removal of insulation and changeout of the three detectors as planned. However, the workers were not able to fully latch one of the detector wells to its normal configuration and additional entries and work were to be initiate (Note: BG&E did not detect the failuro of personnel to wear SWP prescribed dosimetry on April 9,1998, through normal program oversight activities. Rather, ,
the deficiency was detected on April 16,1998, as a result of SIFT review of the I unplanned worker exposure event that occurred later on April 9,1998.)
l On the morning of April 9,1998, a second work crew was preparing to re-enter t'ne i reactor cavity to attempt to relatch the detector well. A pre-job briefing was conducted for this planned work. The radiation survey data collected early the morning of April 9,1998, was used for pre-job planning purpose The day shift zone technician, responsible for radiological oversight of this work activity, did not attend the complete integrated pre-job brief for the work. Rather, i he attended the last several minutes of the brie At the pre-job briefing, a senior radiation protection technician (acting as the radiological controls shift supervisor) calculated an incorrect stay time stay for the worker's entry into the annulus. The calculation for the stay time at the bottom plate (10 minutes to sustain 600 millirem in a 6,000 mR/hr fieid) was incorrec The actual stay time should have been 6 minutes. The stay time was not verified to ;
be correct by any individua BG&E Radiation Protection Procedure 1-132, Revision 1, provides requirements and responsibilities for radiation safety personnel to implement radiological coverag Section 6.1.F of that procedure required radiation safety personnel to perform SWP requirements, i.e, assure that all SWP requirements are met and that radiological conditions and worker dose are monitored. The special SWP (SWP No.1312, dated March 31,1998), stated that work coverage radiation safety technicians shall determine stay times for all workers entering high radiation areas based on the most current survey dat {
I
. \
,
.
!
The failure to properly determine stay time for workers entering high radiation area is an apparent violation of radiation protection procedures requirad by Technical Specification 6.4. (eel 50-317/98-05-01C)
The Radiation Protecti: dupervisor, responsible for all operational radiological controls, was unaware of the planned re-entry into the annulus to attempt to relatch the instrument well. The supervisor was under the assumption that the work had been successfully completed the previous shift. No radiation protection supervisor attended the pre-job briefin One l&C technician was assigned the task to attempt to relatch the detector well and was provided with special dosimetry and alarming SAIC teledosimetry, as required by the S?'P. The SAIC teledosimetry remote monitoring system, PD(E)-4, consisted of five separate radiation detectors that were placed on the right and left thigh, the right and lef upper arms, and the chest. Each dosimeter provided a separate readout of radation exposure and dose rate to the whole body. The data was transmitted to a re note console set up on the 69' elevation of the reactor containment and monitored by a contract radiation protection technicia Two contractor radiation protection technicians were assigned to provide radiological coverage for the task. One technician entered the reactor cavity to perform direct oversight of the worker while the second technician initiated actions to set the SAIC alarm setpoints and provide real time monitoring of the workers entry into the annulus from the remote console. The technician who entered the reactor cavity forgot his extendable radiation survey meter and had to hang down a portable hand held meter into the annulus to check radiation dose rates. This hampered effective radiological coverage of the worker's entry into the annulu The day shift zone technician, responsible for radiological oversight of the work activities, observed that the contractor technician, operating the SAIC radiation teledosimetry system, was having difficulty using the equipment. This was the first time the contractor technician used the SAIC system for high radiation area job coverage. The lead techn.'cian assisted the individual for awhile but did not provide oversight of the individual's use of the equipment, He subsequently left the area to uversee non-high radiological risk work on the 69 foot elevation of the reactor containment. There was no other radiation protection supervisory oversight at the work locatio Radiation Protection Procedure RSP 1-129, Revision 2, Operation of the SAIC Remote Monitoring System, required in Section 6.2, that the PD(E)-4 operating parameters be set per Attachment 2. Attachment 2 required, that the alarms for integrated dose and dose rate be set at the dose and dose rate limits specified by the SWP. SWP No.1312, dated March 31,1998, specified a dose limit of 600 mR and a dose rate of 8,000 mR/h e
.
The technician setting the dose alarms, did not set them as required by procedur The alarms were not properly set on three (right and left thigh and left arm) of the five detectors. Three detector anrms were left at the calibration alarm setpoints used for testing the equipment (25 mR integrated dose and 2.78 R/hr dose rate).
The failure to set the alarm setpoints to the proper alarms is an apparent violation of radiation protection procedures required by Technical Specification (eel 50-317/98-05-01D)
Radiation protection procedure RSP 1-129, Revision 2, also required in Section 6.3, Issuing a PD(El-4, that the applicable information specified on Attachment 5, be recorded on Attachment 5 or a similar form. The applicable information included detector serial number, location, dose alarm, and dose rate alarm. When the PD(E)-4 was issued to an I&C technician entering the annulus, the applicable information was not recorded on Attachment 5 or a similar form. The failure to record SAIC data is an apparent violation of radiation protection procedures required by Technical Specification 6.4. (eel 50 317/98-05-01E)
The l&C technician entered the annulus area to attempt to relatch the detector well about mid-morning of April 9,1998. Upon his entry into the annulus, an area with dose rates ranging between 2,000 mR/hr and 6,000 mR/hr, the three improperly set dosimeters, alarmed (based on review of detector printouts) within about 30 seconds of his entry. The worker and radiation protection personnelin the reactor cavity were not able to hear the alarms. The contractor radiation protection technician, performing real-time monitoring of the dosimetry data transmitted from the detectors and displayed on a computer screen, did not react to the alarms which were clearly indicated in color with warning remarks. The technician took no action to remove the worker from the area. Although the technician was in voice communication, via speaker box, with the technician on the 44 elevation of the reactor cavity, he did not inform that individual of the alarms. Rather the technician continued to monitor the chest dosimeter, which had not alarmed. Also, the left thigh dosimeter encountered radiation dose rates in excess of the SWP specified dose rate limit (8,000 mR/hr) but the technician took no actio Radiation Protection Procedure 1-132, Revision 1, requires in Section 6.1.F.5., that if any unexpected alarms or radiological conditions are encountered, affected t personnel are to be instructed to leave the area. Although the radiation protection technician, monitoring the worker's entry encountered unexpected alarms and unexpected radiological conditions (i.e., three SAIC detectors alarmed and dose rates in excess of SWP limits were encountered) the individual did not stop the work and instruct personnel to exit the area. Further, the left thigh dosimeter's integrated dose exceeded the allowable SWP dose limit and the worker was permitted to continue to work. The failure to instruct personnel to exit the area upon encountering unexpected alarms and radiological conditions is an apparent violation of radiation protection procedures required by Technical Specification (eel 50-317/98-05-01F)
_
.
&
As the chest detector integrated dose approached 510 millirem a decision was made by the contractor technician in the cavity to remove the worker from the are As the worker was exiting the area, the contractor technician in the reactor cavity heard the detector alarm, directed the individual to leave the area, and subsequently reviewed the detector alarm status on the computer console. The technician determined that the integrated dose for the left thigh (950 millirem) exceeded the SWP shift dose limit (600 millirem). The chest dosimeter, which was being solely monitored by the contractor technician at the SAIC console, indicated 525 millire BG&E Radiation Protection Procedure 1-132, Revision 1, required in Section 6.1.F.4., that if stay times are used for dose control, then radiological controls personnel were to monitor dose, dose rates, and stay times per the SWP. The technician in the reactor cavity controlling the worker's exposure in the reactor annulus was using stay times, as required by the SWP (SWP No.1312) for dose control purposes, and was relying on the real-time integrated dose called out to him by the technician monitoring the SAIC system, as the integrated dose for stay time
- purposes. The SWP also required that sacrificial dosimetry (a 0-1.5 R direct reading L dosimeter) be worn and be positioned on the whole body at the location where the highest dose rate field is expecte During the l&C technicians work in the reactor annulus, BG&E did not properly monitor dose, dose rates, or stay times per the SWP as follows
-
RP personnel did not monitor dose properly in that the contractor technician monitoring SAIC teledosimetry readouts, did not monitor critical dose parameters for the worker (i.e., points of highest whole body exposure) as required by the SWP. The contractor technician monitored only one of five SAIC detectors on the I&C technician for dose. The dose provided by the specifically observed detector (chest) was not the highest integrated dose to any portion of the whole body; rather the left thigh sustained the highest external dose. Consequently, the worker was allowed to remain in the high radiation area beyond the limit specified by the SW RP personnel did not monitor dose rates properly in that the contractor l technician took no action to re-evaluate work controls and stay time when one of the SAIC detectors (left thigh) aisrmed after detection of radiation dose rates in excess of the dose rate limit specified on the SW RP personnel did not use or place sacrificial dosimetry on the whole body at the location where the highest dose rate field is expecte The failure to properly monitor radiation dose, dose rate, and stay time is an apparent violation of radiation protection procedures required by Technical
- Specification 6.4. (eel 50-317/98-05-01G)
_ - _ _ _ _ _ _ _ _ _ _ _ _ _
<
.
.
'
The zone technician was to have worn an alarming dosimeter during his entry into the reactor annulus to perform surveys in accordance with the applicable Specific radiation Work Permit (SWP. No.1312, dated March 31,1998). Although this individual indicated an ALNOR (RAD-100) alarming dosimeter was worn, no indication of sign-out and preparation of such a dosimeter was identifie BG&E Radiation Protection Procedure RSP 1-124, Operation of the ALNOR System, Revision 2, required in Section 6.4. K. that the issuance of the RAD-100 ALNOR be recorded on a Form similar to Attachment 4 of the procedure or an approved computer data base. No such record was identifie The failure to record issuance of a RAD 100is an apparent violation of radiation protection procedures required by Technical Specification 6.4 (eel 50-317/98-05-l 01H) s As a result of the above problems, BG&E implemented additional corrective actions I and initiatives to enhance radiological controls for outage work activities. These are discussed in Section R BG&E processed the special dosimetry worn by the workers who entered the annulus and concluded that 1) maximum exposure to anyone worker who did not wear an ALNOR was 127 millirem; and 2) the maximum exposure of the worker
,
who entered the annulus with incorrectly set SAIC dosimetry was 763 millire Conclusion BG&E's radiologi;al controls for replacement of nuclear instrumentation detectors in the Unit 1 reactor annulus on April 9,1998, were ineffective. Eight examples of failure to implement radiation protection procedures for high radiation area work as required by Technical Specification 6.4. were identifie R1.3 Unit 1 Outaae - General Exoosure Controls Scope The inspectors selectively reviewed external and internal exposure controls. The inspectors reviewed work in progress, applicable documentation, and interviewed cognizant personnel. In particular, the inspectors reviewed the adequacy and
,
effectiveness of immediate and interim corrective actions taken following the April 9,1998, unplanned worker exposure event (discussed above). The inspectors attended various pre-job planning meetings and briefings for various work activitie Observations and Findmos BG&E established and implemented a number of corrective actions following the April 9,1998, unplanned worker external exposure event to enhance radiological contrnis for Unit 1 outage work activities. These actions were outlined in BG&E's April 27,1998, letter to the NRC and were supplemented by additional corrective actions documented in NRC Confirmatory Action Letter No. 1-98-006, dated
' April 29,199 ___ __-
, .
.
Pre-job briefing activities for inspection of internal core instrumentation (ICl) wires, a designated "high risk" task, were comprehensive and thorough, and addressed l relevant safety aspects. Radiological surveys for this task properly characterized
- conditions. Radiation protection technir5ns, responsible for providing radiological coverage, were trained and qualified, and provided proper radiological controls for tasks. Radiation Protection Supervisors provided active oversight of the planning and preparation of "high risk" activitie '
The planning meeting for' core barrel inspection activities was comprehensive and thorough. Preliminary planning and preparation activities were underway for the Unit 1 reactor cavity drain down and decontamination, reactor vessel head set, and
~ inspection of the outer vessel wallin the Unit 1 reactor annulus. Appropriate station personnel were in attendance at briafing and planning meeting General access controls to high radiation areas was effective. Areas were properly posted and additional high radiation area warning postings were provided at the approach to high radiation areas. SWP specified electronic dosimeter dose and dose rate alarm setpoints were found to be reasonable relative to expected dose rates and planned exposures. Radiological surveys were complet BG&E properly controlled airborne radioactivity for the work activities reviewe Lapel (breathing zone) air samples were predominately collected for exposure assessment purposes and no significant internal exposures were identified as of the end of the inspection. The internal exposure control program provided for ready identification and generally conservative assessment of apparent instances of internal exposur I Conclusions BG&E implemented a number of corrective actions and initiatives following the April 9,1998, unplanned worker exposure event, including enhanced review and oversight of work activities by radiation protection supervisory personnel. Planning and preparation for work activities reviewed was comprehensive and H woug BG&E provided effective control of airborne radioactivity and no signi 4 't internal
.
exposures were identified as of the end of the inspectio R8 Miscellaneous RP&C lasues R8.1 Confirmatory Action Letter Backaround and Scope (92703)
As a result of the continuing radiological control related problems at the Calvert Cliffs Nuclear Power Station, the NRC issued Confirmatory Action Letter (CAL)
No.1-98-006, dated April 29,1998. That CAL stipulated that, in addition to the immediate and long term corrective actions to improve the radiation safety during the Unit 1 outage, outlined in its April 27,1998, letter to the NRC, the licensee was to immediately clarify and supplement actions as specified in the CAL.
- _ _ _ _ _ .
!
l
\
l*
l
.
Among other commitments documented in the CAL, the licensee committed to provide periodic oversight of pre-job planning activities sufficient to assure that appropriate radiation safety controls are established and integrated with the task and that radiation safety control requirements are effectively communicated to personnel. Also, the licensee was to provide direct oversight of field activities whenever actual higher risk radiological work was being conducted to assure that planned radiation safety controls were effectively established and implemente The CAL also confirmed the licensee's commitment to provide independent surveillance and audits to determine the effectiveness of corrective actions; and assess the quality of ongoing radiological control activitie The inspector reviewed the implementation of the licensee's commitments documented in the CAL and the corrective actions outlined in the April 27,1998, letter to the NRC. The inspector reviewed selected on-going work activities, toured the reactor containment, and attended pre-job planning meeting Observations and Findinas BG&E implemented the provisions of CAL ltems A.1., A.2., and A.3. relative to task planning, briefing and oversight of field activities. BG&E established special guidance in a memorandum dated May 8,1908, regarding personnel responsibilities l for oversight activities and pre-job planning and briefing. The guidance provided for enhanced supervisor oversight of work by the task and radiation safety organizations. BG&E engaged the services of an independent assessor to assess the quality and performance of ongoing radiological control activities as stipulated in CAL ltem B.1. and initiated actions to fulfill the commitments outlined in CAL ltems B.2., and B.3. Work force supervisors and radiation safety supervisors were ;
'
providing direct oversight of "high risk" work activities. Radiological controls performance expectations were discussed and communicated at work planning meetings (e.g., core barrel removal, and reactor vessel head set). Conclusions i BG&E was effectively implementing its commitments to the NRC as documented in NRC CAL No. 1-98-006, dated April 29,199 R8.2 (Closed) Violation)(50-317& 50-318/98-03-01) Failure to perform surveys as reauired by 10 CFR 20.1501(a)to ensure conformance with 10 CFR 20.1703 (a)(3)
BG&E implemented the corrective and preventative actions outlined in its April 20, 1998,lettar in response to the NRC letter and Notice of Violation dated March 20, 199 ;
R8.3 (Closed)(Violation)(50-317& 50-318/98-03-02) Failure to post an airborne radioactivity area as reauired by 10 CFR 20.1902(d)
BG&E implemented the corrective and preventative actions outlined in its April 20, 1998, letter in response to the NRC letter and Notice of Violation dated March 20, 199 .
.
V. Manaaement Meetinas X1 Exit Meeting Summary The inspector meet with licensee repruentatives on April 24, and May 15, and May 20, 1998. The inspector summarized the purpose scope and findings of the inspection. The licensee acknowledged the findings presente l
.
.
PARTIAL LIST OF PERSONS CONTACTED Licensee C H. Cruse, Vice-President - Nuclear Energy R. C. Gradle, Compliance Engineer W. Holston, General Supervisor, Mechanical Maintenance P. Jones, ALARA Coordinator P. Katz, Plant General Manager T. Pritchett, Director - Nuclear Regulatory Matters S. Sanders, General Supervisor, Radiation Safety L. Smialek, Senior Plant Health Physicist (Interim Radiation Protection Manager)
W. Spina, Superintendent Nuclear Maintenance (Acting)
W. Paulhardt, Radiation Safety Supervisor-Dosimetry M. Rigsby, Supervisor-Radiation Technical Services R. Wyvill, Radiation Safety Supervisor NflC S. Stewart, Senior Resident inspector F. Bower, Resident 6spector K. Lathrop, Resident inspector
,
,
L_.___________.___
.
.
INSPECTION PROCEDURES USED IP 83750: Occupational Exposure IP 92703 Confirmatory Action Letters IP 92904: Follow-up - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-317/98-05-01 A eel Failure to implement Radiation Pro , ion Procedures Relative to Calculation of Stay Times 50-317/98 05-01B ' eel Failure to implement Radiation Protection Procedures Relative To Documentation of issuance Of Alarming Dosimeters 50-317/98-05-01 C eel Failure to implement Radiation Protection Procedures Relative to Calculation of Stay Times 50-317/98-05-01 D eel Failure to implement Radiation Protection Procedures Relative to Setting of Dosimeter Alarm Setpoints 50-317/98-05-01 E eel Failure to implement Radiation Protection Procedures Relative to Documenting Dosimeter Alarm Setpoints 50 317/98-05-01F eel Failure to implement Radiation Protection Procedures Relative to Removal of Personnel From Areas During Unexpected Radiological Conditions 50-317/98-05-01G eel Failure to implement Radiation Protection Procedures Relative
,
to Monitor Radiation Dose, Dose Rate, and Stay Tim /98-05-01H eel Failure to implement Radiation Protection Procedures Relative to Documentation of Alarming Dosimeter issuance
]
Closed 50-317&318/98-03-01 VIO Failure to perform surveys as required by 10 CFR 20.1501(a)to ensure conformance with 10 CFR I
20.1703 (a)(3)
50-317&318/98-03-02 VIO Failure to post an airborne radioactivity area as required by 10 CFR 20.1902(d)
Uodated None i
I I
l L
_ _ _ _ _ _ _ -_____ _ ___________ _ _ _ __ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ .
,..
.
LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable CDE Committed Dose Equivalent CEDE Committed Effective Dose Equivalent DAC Derived Air Concentration eel Escalated Enforcement Iten:
HP Health Physics RCS Reactor Coolant System RP Radiation Protection RPIP Radiation Protection improvement Plan RPM Radiation Protection Manager l RWP Radiation Work Permit SIFT Significant incident Finding Team SWP Special Work Permit TEDE Total Effective Dose Equivalent TL Thermoluminescent Do,simeter URI Unresolved item