IR 05000317/1998007

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Insp Repts 50-317/98-07 & 50-318/98-07 on 980531-0717. Violation Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support
ML20236V302
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 07/29/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236V295 List:
References
50-317-98-07, 50-317-98-7, 50-318-98-07, 50-318-98-7, NUDOCS 9808030068
Download: ML20236V302 (16)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

License No DPR-53/DPR-69 Report No /98-07 & 50 318/98-07 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 Dates: May 31,1998 through July 17,1998 Inspectors: J. Scott Stewart, Senior Resident inspector Fred L. Bower Ill, Resident inspector Tim Hoeg, Resident inspector Approved by: Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects

I 9800030068 980729 *?

PDR ADOCK 05000317 G PDR

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EXECUTIVE SUMMARY Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection Report Nos. 50-317/98-07and 50-318/98-07 This inspection report includes aspects of BGE operations, maintenance, engineering and plant support. The report covers a seven week period of resident inspectio P_Ipnt ODerations

' During Uni't 1 start-up and power ascension, the inspectors observed that detailed pre-job briefings were held, operations supervisors provided good oversight of control room activities, and reactor engineering personnel were observed providing good direction and oversight of test procedures. The inspectors also observed excellent communications between the operators, engineers, and supervisors and proper use of procedure Engineering oversight of the service water, main turbine, and feedwater systems during the start-up was very good and contributed to an event-free transition to power operatio Operations department actions to reduce the number of mispositioning events have been effective and the heightened sensitivity to mispositioning by tracking these events was a good safety practic j The performance by the nuclear fuel operations staff during fuel transfer to the i Independent Spent Fuel Storage Installation was good, with appropriate concerns for safety, radiation controls, and foreign materials exclusion. Communications between operators, radiation safety technicians, and reactor engineering personnel were clear and concis Maintenance Surveillance testing was done in a well controlled manner consistent with safety requirements. Pre-evolution briefings were detailed and included discussions of potential problems and contingency plans. Testing was sufficient in scope to demonstrate that the subject equipment would perform their required safety functions. Engineering personnel provided effective maintenance and surveillance testing oversigh Enaineerina The BGE engineering staff responded appropriately to ABB Combustion Engineering l concerns regarding an error in the limiting hot channel departure from nucleate boiling ,

determination for both units. The BGE evaluation was completed in a timely manner and 1 included an appropriate engineering evaluation for continued operability and assurance of margins of nuclear safet j ii

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Executive Summary (cont'd)

Plant Sunoort A testing technician exhibited poor contamination control practices whle working across a contaminated area boundary. The absence of clear contamination centrol policies and procedures, mis-communication of radiation safety instructions, an6 incomplete training were identified as contributing causes for this event. Overall, this event represented ;

continued poor radiological control practices at the facilit '

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TABLE OF CONTENTS 1 F

EXEC UTIVE S U M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii TABLE O F. C O N TENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv -

Summ ary of Plant ' Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

i 1. O pe ra tion s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0 Conduct of Operations ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Observations and Findings (71707) ................ 1

'01.2 Observation of Spent Fuel Pool Operations . . . . . . . . . . . . . . . . . 2 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3  ;

08.1 (Closed) LER 50-317 & 318/97-006: Cable Spreading Room Halon l System Out-of-Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 i

11. M aint e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 M1 - Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 ,

l M1;1 Routine Maintenance Observations ......................3 '

M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . 4 Ill . Enginee ring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 E (Closed) LER 50-318/98-OO2, Failure of Handswitch Contacts t o Clo s e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 .i E8.2 BGE Response to Thermal Hydraulic Margin Loss . . . . . . . . . . . . . 6 l l

I V.~ Pl a nt S u pp ort . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 R4' Staff Knowledge and Performance in RP&C .....................7 R4.1 ' Contamination Controls During Pump Surveillance Testing . . . . . . 7 P1 Conduct of Emergency Planning Activities .....................10 P1.1 Emergency Response Drill . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1  !

X1- Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 j

'X2 Systematic Assessment of Licensee Performance (SALP) Management Meeting Sum m ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 X3 License Renewal Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 ATTACHMENTS

! Attachment 1 - Partial List of Persons Contacted l Inspection Procedures Used items Opened, Closed and Discussed iv l

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Report Details Summarv of Plant Status At the beginning of the inspection period Unit 1 was shutdown in a refueling outag Power operation resumed on June 6,1998 and full power was achieved on June 13, 1998. Unit 1 reduced power briefly on June 16 to repair a failed cooling fan blade on one of the station transformers. Unit 2 operated at full power through the entire inspection period, except for a planned power reduction to 83% on June 13 and 14 to perform testing and maintenanc I. Operations i01 Conduct of Operations 01.1 General Observations and Findings (71707)

Plant operations were conducted safely with a proper focus on nuclear safet Unit 1 was restarted and returned to full power from a refueling outage during the inspection period. The start-up was conducted in accordance with a series of special test procedures that covered pre-critical testing, the initial approach to criticality, low power physics testing, and power escalation. During unit start-up and power ascension, the inspectors observed that detailed pre-job briefings were held, operations supervisors provided good oversight of control room activities, and reactor engineering personnel were observed providing good direction and oversight of test procedures. The inspectors also observed excellent communications between the operators, engineers, and supervisors and proper use of procedure The inspectors verified that core physics measurements were within expected limits. Engineering oversight of the service water, main turbine, and feedwater systems during the start-up was very good and contributed to an event-free transition to power operatio During the Unit 1 refueling outage, the number of control room deficiencies and associated compensatory measures were reduced. Upon reactor restart, the number of outstanding control room deficiencies and compensatory measures were -

within the goals established by BG On Unit 2, the inspectors observed that daily plant operations were conducted safely and in accordance with BGE operating practices. The inspectors conducted reviews of ongoing plant operations and observed that overall plant staff conduct

? was professional and safety-conscious. Operators were aware of the status of l- plant equipment, properly used three-way communications, and effectively l_

implemented plant procedures. Supervisory oversight was appropriat Following a number of valve, switch, and breaker mispositioning events in 1997, the operations department commenced more formal tracking of these events. A mispositioning event, as defined by BGE, is when a component is placed in a position other than that required by procedure, as a result of a failure in human performance or a failure in the work process. In addition, the event is not identified or corrected until after completion of the evolution during which the mispositioning i

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occurred. ' Valve, switch, or breaker mispositionings that resulted in an operational transient, trip, or near miss were also tracked. As a result of this heightened

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sensitivity to proper valve, switch, and breaker positioning, the rolling average of mispositioning events by operations department personnel had declined from an average _of two per month to less than one per month. Non-operations department mispositioning events had not substantially improved, but remained at about one per month. The inspectors considered the operations department actions to reduce the number of mispositioning events to have been effective and the heightened sensitivity to mispositioning by tracking these events to have been a good safety practic .2 Observation of Spent Fuel Pool Operations a. - Insoection Scone (71707)

The inspectors observed and assessed spent fuel movements from the Unit 1 spent fuel pool (SFP) racks to a submerged storage cask. Other operations to close and seal the cask and to transfer the casks to the Independent Spent Fuel Storage Installation (ISFSI) were also observed. The inspectors focused on radiological control practices during the cask sealing activities, Observations and Findinas The inspectors observed a total of four spent fuel assemblies being transferred from the spent fuel racks to the dry storage cask submerged in the spent fuel pool in preparation for transfer to the ISFSI. The crane operator was observed to be experienced and knowledgeable in the operation of the SFP bridge crane. The operator followed BGE procedures while performing the evolution. Foreign material exclusion (FME) practices were used by all personnel entering the controlled area around the SFP. Precise repeat back communication was observed between the operator and the reactor fuels engineer responsible for inventory controls of the spent fue Detailed surveys of the radiation and neutron exposure rates around the cask were

- observed during the cask sealing and transfer phase and prior to work that could result in changes in radiation levels. The surveys were recorded on maps and discussed with workers prior to entry into the radiation areas around the cask. Stay l times were calculated e.nd verified for individuals entering high radiation area Management and supervisory oversight was apparent and effective for worker dose l control. For example, prior to the loading of the first cask, a pre-job brief of the activity was led by the plant general manager. During the pre-job brief, contingency l actions were thoroughly discussed and verifications were made of preparation Conclusions The performance by the nuclear fuel operations staff during fuel transfer to the Independent Spent Fuel Storage Installation was good, with appropriate concerns for safety, radiation controls, and foreign materials exclusion. Communications

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l 3 L between operators, radiation safety technicians, and reactor engineering personnel i were clear and concis Miscellaneous Operations issues 08.1. (Closed) LER 50-317 & 318/97-006: Cable Spreading Room Halon System Out-of- i Servic On July 22,1997, the cable spreading room halon system was rendered inoperable l by a tag-out for scheduled maintenance on the No.11 control room heating, l ventilation, and air conditioning system. However, the cable spreading room (CSR)

halon system was not declared out-of-service and was not returned to service for approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />. During this 35-hour period, the associated Technical Specification action requirement for an hourly fire watch was not implemente BGE determined that the cause of the event was poor review of the package by operations personnel. A root cause assessment identified that the operators overlooked that the CSR halon system was out-of-service, even though the

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requirements for entering the applicable Technical Specification action statement

' was specified in the tag-out instructions. During the time that the halon system was out-of-service, no fires occurred and the fire detection system in the room remained operable. As a corrective measure, BGE discussed the occurrence with all i operations personnel. Additional corrective actions included enhancements to the safety tagging process and new caution labels. This non-repetitive, licensee-identified and corrected . violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-317&318/98-07-01). The LER is close i 11. Maintenance M1 Conduct of Maintenance M1.1 Routine Maintenance Observations .!

Inspection Scope (62707) . The inspectors reviewed maintenance activities and focused on the status of work that involved systems and components important to safety. Component failures or system problems that affected systems included in the BGE maintenance rule ,

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program were assessed to determine if the maintenance was effective. The l- inspectors directly observed all or portions of the following work activities:

MO1199800288 Unit 1 High Pressure Main Turbine Leak Sealing MO2199800494 Clean and Inspect 2A Emergency Diesel Ventilation MO1199704442 Sample Auxiliary Feedwater Turbine Oil ,

MO2199801131 21 High Pressure Safety injection Lubrication  :

MO2199706098 21 Component Cooling Water Heat Exchanger Cleaning MO2199705911 21 Containment Spray Pump Overhaul

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! Observations. Findinas. and Conclusions

,. Maintenance rule (Rule) implementation for the auxiliary feedwater system was l' examined. The inspectors noted that BGE divided the auxiliary feedwater system into eight subsystems for each unit, including: four flow headers; one unit to unit cross-tie; two steam-driven pumps; and one motor-driven pump. Six of the sixteen subsystems (both unite) were considered a(1) under 10 CFR 50.65 criteria. Goals for those subsystems under a(1) were either implemented or under development for recently identified problema. Those auxiliary feedwater subsystems that were not a(1) were tracked for unavailability and reliability in accordance with provision a(2)

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of the Rule. Maintenance rule implementation for the auxiliary feedwater system was appropriat BGE identified several cases where compressed gas cylinders had been stored in cor ditions contrary to BGE safety expectations. After correcting each case, BGE issued a safety alert to plant personnel reminding them of proper storage practices for compressed gas. These practices included the use of valve protection cans, f cylinders secured in an upright position, and separation of oxygen cylinders f.om

! combustible materials storage. The inspectors did not observe any improperly l

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stored cylinders and considered the licensee's identification of the storage weaknesses, immediate correction of deficiencies, and issuance of the safety alert to plant personnel to be good corrective action.

L I M1.2 Routine Surveillance Observations a. Insoection Scoos (61726)

The inspectors observed all or portions of the following surveillance tests:

L STP-O-73D-1 Charging Pump Performance Test ll STP-O-73F-1 Boric Acid Pump Performance Test STP-M-2128-1 Channel "B" Reactor Protection System Functional Test STP-M 212C-1 Channel "C" Reactor Protection System Functional Test STP-O-73J-1 Low Pressure Safety injection Pump Operability Test STP-O-73 K-1 Containment Spray Pump Operability Test (Unit 1)

STP-O-5A-1 Auxiliary Feedwater Quarterly Test (Unit 1)

STP-O-7312 HPSI Pump and Check Valve Quarterly Operability Test L STP-O-73K-2 Containment Spray Pump Operability Test (Unit 2)

b. Observations and Findinas The inspectors found that the selected surveillance activities were performed safely and in accordance with approved procedures. Test details were discussed at a pre-test briefing followed by a question and answer session attended by all involved testing participants. The test participants were knowledgeable of their assigned duties and responsibilities. During observation of testing in the control room, the licensed operators were noted to perform the tests in a well controlled manner that included the use of self-verification, peer verification, and supervisory oversigh _ _ _ _ _ _ _ _ _ _ _ - __ _-_______- _ _ -_

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During the observation of testing in the plant, the auxiliary operators were observed using good self-checking and three-way communication techniques. Except as noted in section R4.1, test personnel were noted to demonstrate good radiological ;

protection practice The pre-test briefing for the high pressure safety injection (HPSI) quarterly test included a detailed discussion of applicable technical specifications, proper communications techniques; industry events; and past plant experiences. The briefing also included a safety hazards discussion and a review of contingency plans should unexpected results be obtained. The inspector noted that the participants maintained communications with the control room, as required by technical specifications, when the turbine pump discharge isolation valves were shut per the test. Engineering personnel observed the test and performed preliminary evaluations of the test results as the data was obtained. Following the testing, bearing oil samples were properly obtained and evaluated for bearing degradatio No problems were found and the test was completed satisfactorily, l

c. Conclusions i Surveillance testing was done in a well controlled manner consistent with safety requirements. Pre-evolution briefings were detailed and included discussions of potential problems and contingency plans. Testing was sufficient in scope to demonstrate that the subject equipment would perform their required safety functions. Engineering personnel provided effective maintenance and surveillance testing oversigh i 111. Enaineerina E8 Miscellaneous Engineering issues l E (Closed) LER 50-318/98-002, Failure of Handswitch Contacts to Close 1 The inspectors reviewed Licensee Event Report (LER)98-002 which described a handswitch failure that prevented opening the steam supply  ;

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valves from the 21 steam generator to the Unit 2 Auxiliary Feedwater (AFW)

pumps. BGE determined the cause of the failure was that the contacts in the lower contact block of the handswitch did not close. The immediate corrective actions included: (1) inspecting and repairing the handswitches; (2) a root cause analysis was initiated; and, (3) a compensatory measure was established (until the root cause was identified) to electrically verify that the " auto" position contacts for this handswitch, and similar handswitches in -

l the AFW system, were closed after the handswitches are cycle .

The inspector reviewed the completed root cause analysis (RCA) and found .

the RCA appropriate in scope and level of detail. Initial testing of the same model handswitch was unable to reproduce the failure. However, adjustments were made to the switch to induce misalignment and ]

mispositioning of parts. From subsequent testing, the BGE concluded that i l i  ;

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misalignment and/or mispositioning could cause degradation of switch

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~ being developed to change the switch contacts. The inspector determined that until the design change can be installed, the operations shift turnover sheet is carrying a note to ensure that maintenance personnel verify the handswitch contacts in the " auto" position after the handswitch is cycle The inspectors concluded that BGE responded appropriately to this event and that no safety consequences resulted. This LER is close E8.2 BGE Response to Thermal Hydraulic Margin Loss . Insoection Scope (37551)

A thermal hydraulic margin loss was identified to BGE in a letter from ASEA

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Brown Boveri- Combustion Engineering (ABB-CE), dated July 9,1998. The inspectors reviewed the BGE response to the information and focused on-immediate operability determinations and corrective action Observations and Findinas-ABB Combustion Engineering informed BGE of deficiencies in the core operating limits analyses for the Calvert Cliffs Unit 1 Cycle 14 and Unit 2 -

Cycle 12. -The deficiencies involved a departure from nucleate boiling margin loss of approximately 4% for.each unit, due to an error in identifying the limiting hot channel. BGE engineering immediately initiated an issue report and performed an operability determination for each unit. The issue report described the concern and considered operability and deportabilit The BGE operability determination concluded that the reactor protection system low flow trip and in-core monitoring systems assured reactor protection during both steady state and transient conditions. However,

- BGE engineering recommended that an administrative reactor coolant system flow limit higher than the current technical specification (TS) value

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be implemented for Unit 1. The administrative limit provides additional margin to the TS limit. Combustion Engineering informed BGE that a 10 CFR Part 21 report on the issue would be submitted. The administrative flow limit was adopte BGE nuclear engineering and vendor audit personnel have identified several errors and quality concerns related to calculations performed by ABB-C BGE initiated an issue report to document these problems in the corrective actions program. BGE plans to evaluate these concerns to determine if a i generic concern exists. The inspectors determined that BGE was properly responding to potential generic concerns related to the quality of nuclear engineering calculations performed by vendors.

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7 Conclusions The BGE engineering staff responded appropriately to ABB Combustion

. Engineering concerns regarding an error in the limiting hot channel departure-from nucleate boiling determination for both units. The BGE evaluation was

' completed in a timely manner and included an appropriate engineering

evaluation for continued operability and assurance of margins of nuclear

- safet IV, Plant Support R4 Staff Knowledge and Performance in RP&C R4.1 Contamination Controls During Pump Surveillance Testing Scope The inspectors reviewed radiological protection and contamination controls used during surveillance testing of the Unit 1 containment spray pump ' Observations and Findinas On June 18, the inspectors observed an operator and a test technician performing surveillance testing on the 11 and 12 containment spray (CS)

pumps. The test technician demonstrated good as-low-as-reasonably-achievable (ALARA) radiological protection practices by remaining in a-designated low dose area while the operator aligned the 11 CS pump for the i

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After the pump was started, the test technician took temperature and vibration readings on the CS pump motor. The technician was wearing partial protective clothing consisting of rubber gloves and liners on both hands,' even though the motor was outside the contaminated are !

Subsequently, the technician took vibration readings inside the contaminated '

area on the pump casing. The technician used his right hand to attach a probe to the pump casing and his uncontaminated left hand to operate the monitor, hanging from a shoulder strap. The probe was connected to the monitor via a cable that bridged the contaminated area boundary.- The inspector observed that the cable was not affixed to the contaminated area L boundary to' prevent inadvertent movement into or out of the area, as I required by RSP 1-104, " Area Posting and Barricading". The inspector also ,

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observed that no radiological precautions were taken to ensure that

contamination remained within the contaminated area boundaries and that j the radiation safety technician (RST) was not present at the work are !

After the first set of readings were taken, the technician crossed his left hand into the contaminated area and disconnected the now potentially contaminated cable and probe from each other. The probe accidently  !

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dropped onto the pump skid. The technician then removed both of his hands from the contaminated area, traversed the clean area to the other side of the l pump skid, and used his right hand to retrieve the probe. The technician

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L traversed the clean area again and reached across the contaminated area boundary to connect the vibration probe to a second pump monitoring point.

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The technician then use a now potentially contaminated gloved left hand to l operate the monitor hanging from the shoulder strap.

l The inspectors noted that the practice of exiting and re-entering t' contaminated areas without removing potentially contaminated protective clothing or performing a frisk (to verify that items removed from a l contaminated area were uncontaminated) could lead to the inadvertent spread of contamination. The inspectors questioned the test technician whether adequate contamination controls were being used and the technician responded in the affirmative and continued work. Upon arrival of an RST at the work area, the inspectors discussed their observations and concern Subsequen'ly, t the 12 CS pump was tested and the RST specified additional protective clothing (arm sleeves, in addition to the rubber gloves and liners).

No additional radiological concerns were identified during the performance I testing of the 12 CS pump. Upon completion of the equipment performance j monitoring of each CS pump, the RST performed a swipe survey of the I equipment and determined that it was clean. Upon completion of the surveillance testing, whole body frisks confirmed that the workers were not contaminate The inspectors' observations and concerns were discussed with supervisory

. personnel at the radiological control area (RCA) access point. The inspectors verified that the workers had checked-in at the access point. Access control personnel stated that the workers were instructed to check-in with the RST responsible for the work site prior to starting work. The inspectors ,

determined that, although the operator checked-in with the RST for his tasks, a similar check in was not completed for the tasks planned by the testing technician. The following three concerns were documented by the radiation protection' staff on an issue Report for submittal to the BGE corrective action process: ' (1) the test technician failed to check-in with the responsible RST;

- (2) the technician repeatedly reached into and back out of the contaminated area without removing his protective clothing; and, (3) the technician handled clean material with potentially contaminated glove The inspectors determined that as an immediate corrective action, BGE

' instituted a policy that required continuous RST coverage for working in a contaminated area. BGE also initiated an investigation of the event. On June 19, the Plant General Manager (PGM) issued a memorandum concerning expectations for working in contaminated areas. On June 22, all i radiological work was stopped to conduct two site-wide safety breaks to provide training relative to this event and the PGM's June 19 memorandu I i

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The expectations in the June 19 memorandum included: (1) prior to performing work across a contaminated area boundary, workers would conduct a walkdown with a RST to get job-specific instructions; and, (2) items crossing a contaminated area boundary would be treated as contaminated and would be contained or surveyed during removal from a contaminated are The BGE investigation determined that mis-communication contributed to the technician's failure to check-in with the RST. Consequently, BGE has instituted a policy requiring three-way communication of instructions at the RCA access point. BGE also determined that general orientation training (GOT) instructed workers not to reach over contaminated area boundaries, even though certain plant circumstances, such as the one discussed above, I necessitated reaching across contaminated area boundaries to perform wor Thus, no specific instructions or guidance had been provided for how to work across contaminated area boundaries. Consequently, BGE has initiated action to develop additional practices, policies, and training for working ,

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Calvert Cliffs Administrative Procedurc RP-1-100," Radiation Protection," I Section 5.2.E requires personnel assigned to perform a job in a radiologically controlled area (RCA) to follow special work permit (SWP) and RST instructions. Calvert Cliffs Technical Procedure RSP-1-104, Revision 12,

" Area Posting and Barricading," implements requirements for radiation {

protection, and states in Section 6.11.A, to secure all items crossing into a )

contaminated area at the boundary, to prevent inadvertent movement into or out of the area. The failure of the test technician to follow these radiation

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safety procedures while working around and across the contaminated area boundary of the 11 containment spray pump was a violation of regulatory requirements. (VIO 50-317&318/98-07-02)

l BGE informed the inspectors that the reasons for the violation included: a lack of management expectations (and training) for working across ]

contaminated area boundaries; the failure of the test technician to get radiation controls assistance prior to doing the testing; and a poor questioning attitude for proper contamination controls during the testin Immediate corrective actions were taken, once the problem was identified to plant management, including: the plant general manager memorandum; l discussion with test technicians and operators; a site wide safety break; and l an increase in radiation safety staff oversight of routine work in the auxiliary building. BGE had also initiated improved radiation controls procedures. Full compliance w';.s achieved during the inspection perie j l

c. Conclusions A testing technician exhibited poor contamination control practices while working across a contaminated area boundary. The absence of clear contamination control policies and procedures, mis-communication of l

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radiation safety instructions, and incomplete training were identified as contributing causes for this event. Overall, this event represented continued poor radiological control practices at the facilit P1 Conduct of Emergency Planning Activities 1 P1.1 Emergency Response Drill a. Insoection Scone (71750)

BGE conducted an emergency preparedness drill on July 2,1998. The inspectors observed selected activities in the Technical Support Center l (TSC), Emergency Operations Facility (EOF), and BGE's critique and evaluation following the drill b. Observations and Findinas On July 2, BGE simulated a Unit 1 loss of shutdown cooling while refueling in Mode 6 as an iniciating event for an emergency drill. The scenario escalated and a simulated Alert classification was declared, resulting in the activation of the BGE emergency response organization. The inspectors observed that the response centers were staffed and ready within the time specified in the BGE Emergency Plan. The TSC and EOF personnel referred to their applicable emergency response plan implementation procedures (ERPIP) and simulated the required actions appropriately. Proper three-way communications were observed between the various organizations. The objectives of the drillincluded:

(1) Loss of shutdown cooling detection, assessment, and classificatio (2) Notification of on-site and off-site organization (3) The ability of center directors and key personnel to communicat !

Decay heat removal was simulated as being restored prior to terminating the j drill. In addition, the inspectors observed that the drill controllers provided a j realistic scenario and effectively engaged all drill participants. The drill lasted )

approximately 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ;

i The inspectors observed the post-drill critique conducted by BGE's l assessment organization and the assigned drill evaluators. The evaluators l shared their findings with the group and issue Reports were written to address BGE identified weaknesses. The inspector noted that the BGE critique focused on areas which BGE considered needing improvement. BGE concluded, overall, the drill was a satisfactory training exercis j l l

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c. Conclusion BGE's July 2 EP Drill was realistic and appropriately controlled by the EP staff. The licensee's critique of the drill was detailed, accurate, and self critica V. Manaaement Meetinas X1 Exit Meeting Summary During this inspection, periodic meetings were held with station management to discuss inspection observations and findings On July 24,1998, an exit meeting was held to summarize the conclusions of the inspection. BGE management in attendance acknowledged the findings presente X2 Systematic Assessment of Licensee Performance (SALP) Management Meeting Summary On June 8 and 9,1998, Mr. W. Axelson, Deputy Regional Administrator, Region I and other NRC managers visited Calvert Cliffs Nuclear Power Plan The visit included a site tour and discussions with various site individuals in operations, maintenance, radiation controls, engineering, and quality assurance. On June 9, a public meeting with members of BGE management was held to discuss SALP Report 50-317&318/98-99, dated May 26,199 X3 License Renewal Activities During the week of July 6,1998, an NRC review team visited Calvert Cliffs to conduct license renewal environmental scoping activities. On July 9, 1998, two public meeting were held in the vicinity of Calvert Cliffs to allow the public to comment on the environmental impact survey, being conducted in accordance with 10 CFR Part 5 I

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L I ATTACHMENT 1 l

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PARTIAL LIST OF PERSONS CONTACTED

! EGLE C. Cruse, Vice President- Nuclear Energy Division P. Katz, Plant General Manager K. Collers, Manager, Nuclear Engineering

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L. Wechbaugh, Superintendent, Nuclear Maintenance K. Neitmann, Superintendent, Nuclear Operations T. Pritchett, Superintendent, Techn. cal Support J. Osborne, Acting Director, Nuclear Regulatory Matters S. Sanders, General Supervisor, Radiation Safety

. T. Sydnor, General Supervisor, Plant Engineering M. Navin, General Supervisor, Plant Operations LINSPECTION PROCEDURES USED iP 61726: - Surveillance Observations

. IP 62707:

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Maintenance Observation IP 71707: Plant Operations i

' lP 92700: Onsite Follow up of Written Reports of Evsnts at Power Reactor Facilities -

IP 37551 Onsite Engineering IP 71750 Plant Support Activities ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-317&318/98-07-01 NCV Failure to establish a fire watch for out-of service cable spreading room halon 50-317&318/98-07-02 VIO Failure to follow radiation safety procedures during work in a contaminated area Closed 50 317&318/98-07-01 NCV Failure to establish a fire watch for out-of-service

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cable spreading room halon 50-317&318/98-07-02 VIO Failure to follow radiation safety procedures during work in a contaminated area 50-317&318/97-006 LER Cable Spreading Room Halon System Out-of-Service 50-318/98-002 LER Failure of Passive Handswitch Contacts to Close i

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