IR 05000317/1998011
| ML20199K885 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/19/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20199K853 | List: |
| References | |
| 50-317-98-11, 50-318-98-11, NUDOCS 9901270059 | |
| Download: ML20199K885 (27) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
License Nos.:
DPR-53/DPR-69 Report Nos.:
50-317/98-11 & 50-318/98-11 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:
October 25,1998 through December 12,1998 Inspectors:
J. Scott Stewart, Senior Resident inspector Fred L. Bower Ill, Resident inspector Tim L. Hoeg, Resident inspector Lonny Eckert, Radiation Specialist, Region 1 Jason Jang, Senior Radiation Specialist, Region i Ronald Nimitz, Senior Radiation Specialist, Region 1 Approved by:
Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects 9901270059 990119 PDR ADOCK 05000317 G
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EXECUTIVE SUMMARY Calvert Cliffs Nuclear Power Plant, Units 1 and 2
Inspection Report Nos. 50-317/98-11 and 50-318/98-11 This integrated inspection report includes aspects of BGE operations, maintenance, engineering and plant support. The report covers a seven week period of resident inspection and the results of specialist inspections in radiation protection and effluent monitoring.
Plant Operations in a number of isolated instances, the inspectors identified plant cleanliness concerns. When informed, BGE took action to clean the areas of concern.
An electrical supply breaker for a bank of pressurizer heaters failed to open on demand, resulting in a small electrical fire. The BGE response to the fire was prompt and in accordance with the station pre-planned strategy. BGE intended to send the breaker to a vendor for a complete evaluation.
i Maintenance The inspectors found that the selocted maintenance activities were performed safely and in
accordance with BGE procedures. BGE initiated self-critical reviews of high radiation area work after the jobs were done to establish lessons learned.
Enaineerina BGE identified that a part had been inadvertently not included in the installation of the saltwater strainers for the Unit 1 service water heat exchangers. The absence of this part allowed some strainer bypass flow and may have contributed to recent heat exchanger
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fouling.
Plant Suppoft BGE established, implemented, and maintained an effective program for radiation monitoring system calibrations, including trending and tracking of system reliability.
BGE radiation protection technicians (RST) and supervisors exhibited poor surveillanco documentation practices for some daily radiation monitoring source checks. This problem had been previously identified by BGE and entered into their corrective action program. Corrective actions were being implemented.
BGE established, implemented, and maintained an effective program with respect to response to audit findings and quality control for validating measurement results for radioactive effluent samples.
Effective exposure controls were implemented during spent fuel pool diving and Unit 2 fuel inspection activities.
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i Executive Summary (cont'd)
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E The Radiation Protection improvement Program was being effectively implemented. The work f
planning and control program was modified to incorporate identification and control of work
from a radiological risk perspective. A revised radiation protection organization was being
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implemented to improve oversight and control of activities, and functional position l
descriptions, including responsibilities and authorities, for affected positions were being j
updated. BGE was continuing to revise radiological controls procedures to provide for
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improved control and oversight of radiological work activities.
' Enhanced planning and preparation, from a radiological risk basis, were on-going for the upcoming Unit 2 outage. The work scope was identified and enhanced controls were being established censistent with radiological risk.
BGE was pr forming appropriate radiological controls planning and preparation for replacement of steam generators, i
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TABLE OF CONTENTS
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i EX ECUTIVE SU M M ARY................................................ ii i
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l TA B LE O F C O NT E NT S................................................ iv
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Summary of Plant Status
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I. O pe ratio n s....................................................... 1
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Conduct of Operations...................................... 1 l
01.1 General Comments
...................................1 01.2 Failed Pressurizer Proportional Heater Breaker (Unit 2)........... 2 l
01.3 Observation of Auxiliary Operators......................... 3 11. M ain t e n a n c e..................................................... 4 M1 Conduct of Maintenance..................................... 4 M 1.1 General Comments.................................... 4 M1.2 Routine Surveillance Observations......................... 5 111. En g in e e rin g...................................................... 6 El Conduct of Engineering...................................... 6 E1.1 Missing Part on Unit 1 Saltwater Strainer.................... 6 E8 Miscellaneous Engineering Issues............................... 7 E8.1 (Closed) Licensee Event Report 50-317&318/98-08: Reactor Protective System Technical Specification Error................ 7 E8.2 (Closed) Unresolved item 50-317&318/96-10-03: Old Design issues identified During a BGE Review........................... 7 I V. Pl a nt S u p po rt.................................................... 8 R1 Radiological Protection and Chemistry (RP&C) Controls............... 8 R1.1 Implementation of the Radioactive Liquid and Gaseous Effluent I
Co ntr ol Prog ram...................................... 8 R1.2 General Exposure Controls
..............................9 R1.3 Changes.......................................... 10 R1.4 Unit 2 Outage Planning and Preparation.................... 11 R2 Status of RP&C Facilities and Equipment........................ 12 R2.1 Calibration of Effluent / Process Radiation Monitoring Systems (RMS),
i Calibration of Flow Rate Measuring Devices, and Calibration of Hydrogen Monitors................................... 12 R2.2 ~ (Closed) Unresolved items 50-317&318/97-04-02 and 03; Air Cleaning Systems
...................................13 R3 RP&C Procedures and Documentation
..........................14 R3.1 Radiation Safety Surveillance Documentation................ 14 '
R7 Quality Assurance (QA) in RP&C Activities....................... 15 R7.1 Review of Quality Assurance Activities
....................15 R8 Miscellaneous RP&C lssues.................................. 16 l
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i R8.1 Planning and Preparation For Steam Generator Replacement...... 16 l
R8.2 Corrective Actions For April 9,1998, Reactor Vessel Annulus
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Problem
..........................................16 P8 Miscellaneous EP Issues................................... 18 j
P8.1 Emergency Action Levels Annual Review (IP 717EO)........... 18
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- V. Management Meetings
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. Exit Meeting Summary..................................... 19
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X2 Probabilistic Risk Assessment Meeting Summary................... 19
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X3 Management Meeting Summary............................... 19 i
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l ATTACHMENTS
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Partial List of Persons Contacted Inspection Procedures Used l
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Items Opened, Closed and Discussed
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l List of Acronymns Used
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I Report Detahs
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Summarv of Plant Status
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Unit 1 power was reduced to approximately 30 percent on December 2 because of a problem with control of a main turbine intercept valve. The valve control circuit was repaired that day
and the unit was returned to full power. Otherwise, both reactors operated at full pnwer
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throughout the inspection period except for minor power reductions for routine conder ser waterbox cleaning and turbine valve testing.
j 1. Operations l
Conduct of Operations 01.1 General Comments (71707)
l Plant operations were conducted safety with a proper focus on nuclear safety. Control
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room operators were aware of plant conditions, remained attentive, and conducted shift turnovers in a thorough manner. Communications were formal and in accordance with BGE policies. Control room equipment status was clearly identified. Procedures l
were appropriately used for plant operations. Shift managers provided proper oversight of operations.
i During a tour of plant areas on November 6, the inspectors found the following items in the Unit 1 service water pump room: a bucket of cleaning water and a mop; an unattended work bench that held a live electrical connection and was cluttered with rags, plastic and other potentially flammable trash; a powered electrical plug hanging from piping with about six feet of unattached cord; an unchocked heavy work cart; unattended storage of maintenance equipment, including tools, lubricants, and an open bucket of rags; and an unattached electrical cord on the floor. The inspectors l
considered these items to be potential fire hazards or hazards to personnel should a plant event require entry into the room during an emergency. The on-shift crew was l
informed of the issues and immediate action was taken by the crew to remove trash and stow equipment in accordance with BGE expectations for room cleanliness. During a tour of plant areas on December 1, the inspectors identified a buildup of dust on the ventilation intake louvres for the operating Unit 2 service water pumps and sealant shavings that had been swept into a floor drain in a Unit 2 ECCS pump room. These issues were identified to BGE and corrected on the same day. Following the cleanup, the inspectors had no other concerns. The inspectors considered the cleanliness issues I
to be isolated examples where BGE attention to plant cleanliness had declined. At the I
end of the inspection period, BGE had established an action plan for plant cleanliness including plans to raise expectations of various groups for maintaining areas clean and free of unnecessary debris.
The inspectors reviewed the October 1998 Training Accreditation Evaluation Report of Calvert Cliffs Nuclear Power Plant. The report was prepared by National Academy for l
Nuclear Training (INPO) following a review conducted in July 1998 of maintenance, l
chemistry, radiological protection, and engineering support training programs.
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On December 2,1998, at approximately 2:00 a.m., BGE reduced power on Unit 1 due to the #3 main turbine intercept valve cycling for no apparent reason. The inspectors responded to the site to observe the power change. The power reduction was performed in a safe and controlled manner using BGE approved procedures. System Engineering and instrumentation and Control (l&C) personnel responded to the site to support control room personnel. The plant was stabilized at 25% power and l&C troubleshooting was initiated. The problem was diagnosed as a faulty servo amplifier
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demodulator indicator card. The card was replaced and tested satisfactorily.
Engineering and maintenance support of the power change and system repair was good. Unit 1 was returned to full power later in the day with no problems noted.
01.2 Failed Pressurizer Proportional Heater Breaker (Unit 2)
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Insoection Scoce (71707)
The inspectors reviewed the circumstances of a failed pressurizer heater breaker, including the response of the Calvert Cliffs fire brigade.
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Findinos and Observations On November 11, while establishing conditions to perform a preplanned plant test, the 22 proportional heater breaker failed to open from the control room when the breaker control handswitch was taken to the open position. Control room personnel summoned an auxiliary operator to the breaker location in the 45 foot switchgear room. The operator noted smoke in the vicinity of the breaker. When the operator j
opened the breaker cabinet, increasing smoke and a glowing control power wire were observed. These conditions were reported to the control room and the emergency procedure for a fire in the switchgear room was entered. The fire brigade was summoned to the scene. In parallel, shift personnel pulled the control power fuses from the breaker cabinet and the smoking stopped. The shift manager remained in the control room and provided oversight to the response.
The plant fire brigade responded in full fire readiness. Dry extinguishing materials were staged at the scene. Approximately three minutes after the fuses were pulled, the fire was determined to be out and the fire brigade began to remove smoke from the room in accordance with the station's fire strategy. BGE stationed fire watch personnel with fire suppression equipment in the vicinity of the breaker until plant electricians arrived.
The electricians opened the breaker by repeated cycling of the manual trip lever, then racked out and removed the breaker for troubleshooting.
The fire was found to be limited to the insulation and coatings on the shunt trip coil and associated wiring. The cause of the breaker failure to open was indeterminate at the end of the inspection period. BGE intended to send the breaker to a vendor for an evaluatio _-
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Conclusions A breaker for a bank of pressurizer heaters failed to open on demand, resulting in a small electrical fire. The BGE response to the fire was prompt and in accordance with the station's preplanned strategy. BGE intended to send the breaker to a vendor for an evaluation.
01.3 Observation of Auxiliary Operators a.
Insoection Scooe (71707)
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The inspectors observed and assessed non-licensed equipment operators performing tours of their assigned areas of the plant.
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Observations and Findinas i
On November 17, during backshift hours, the inspectors observed and assessed a non-
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licensed nuclear plant operator (NPO) performing a tour and data collection evolution of the outside areas of the plant. The inspector verified the NPO attended the evening shift turnover where equipment operating status, major work in progress, and plant issues were discussed. The inspector noted that the NPO participated in the shift turnover by presenting the outside equipment status to the rest of the shift personnel.
The operator clearly and accurately communicated the status of this equipment.
The inspector observed that the NPO wore the required safety equipment while touring plant areas.- The operator toured all assigned areas including the main transformers, diesel generators, condensate storage tu.ks, and the intake structure. The NPO verified plant parameters were in compliance with the applicable technical specifications. The NPO was observed correctly checking that the associated equipment was in the proper lineup and functioning satisfactorily. The NPO observed posted safety and security instructions during entry and exit from the various rooms and areas associated with the outide tour. Communications between the NPO and the control room were formal and complete. No abnormalities or out of specification readings were noted by the NPO or the inspector.
On November 22, and 29, the inspectors accompanied the assigned Unit 1 auxiliary building NPO during walkdowns of assigned plant areas. The NPOs were prepared for rounds with keys, flashlight, gloves and radio. Personal protection equipment was used when required. The NPOs were knowledgeable of the radiation work permit and practiced ALARA principles. The inspector determined that the rounds were conducted in accordance with BGE administrative procedure NO-1-2OO, " Control of Shift Activities." The inspector observed that the NPOs performed a thorough inspection for steam leaks. The NPOs wore the required safety equipment and observed appropriate safety practices while conducting the tours. No abnormalities or out of specification readings were noted by the NPO or the inspector.
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Conclusions
The performance of the non-licensed plant operators during rounds was professional
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and thorough with an appropriate focus on safety, equipment status, and observation
' of plant conditions. Communications between plant operators and the control room were formal and complete.
11. Maintenance M1 Conduct of Maintenance M1.1-General Comments a.
Insoection Scope (62707)
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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 program were assessed to determine if the maintenance was effective. Also, the inspectors directly.
observed all or portions of the following work activities:
MO1199803792 Clean Plates 11B Service Water Heat Exchanger MO1199700903 1-_MOV-645 Appendix R Upgrades FH-301 Core Component (Fuel) Receipt inspection i
MO1199803120 Replace #13 HPSI Pump Motor Breaker Switch MO1199801817 1MOV654 - inspect and Lubricate MOV for HPSI Header
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MO1199801680 12 ECCS Room Cooler Anode inspection MO2199803619 Removal of Oil from Unit 2 Reactor Coolant Pump Collection Tank b.
~ Observations and Findinos The inspectors observed selected maintenance activities to determine if the activities were performed safely and in accordance with BGE procedures. The inspectors
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l observed that technicians.were experienced and knowledgeable of the assigned duties.
Pre-job briefings were effective in ensuring that the work was conducted in accordance with BGE work protocols and plans. When applicable, appropriate foreign material exclusion controls were practiced. The inspectors noted that an appropriate level of j.
supervisory attention was given to the work.
p On December 7, BGE personnel entered the Unit 2 containment to remove oil from the i
reactor coolant pump oil collection tank. This job was considered radiologically high risk because of radiation levels in the vicinity of the tank during reactor operation. The pre-job brief was completed using the checklist provided in BGE administrative l
procedure RP-1-102, " Control of Radiation Protection Risk Significant Work." The brief participants displayed good questioning attitudes. Supervisory oversight was provided
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successful completion of the containment entry, the workers completed an effective post-job review to discuss successes and areas for improvement.
The inspectors reviewed the maintenance rule status of the charging subsystem of the chemical and volume control system. The system was of low risk significance and was monitored at the plant level using indicators that included unit capacity factor, equipment forced outage rate, and repetitive functional failures. As of November 1998, the CVCS system was category A(2) under the rule. BGE did maintain a system report card on the CVCS system that included quarterly evaluations of charging pump availability, operator workarounds, and temporary alterations. Charging pump repacking and check valve performance were also monitored and trended. The BGE determination that charging system performance was being effectively controlled using preventive maintenance appeared to be appropriate.
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Conclusions
.The inspectors found that the selected maintenance activities were performed safely and in accordance with BGE procedures. BGE initiated self-critical reviews of high radiation area work after the jobs were done to establish lessons learned.
M1.2 Routine Surveillance Observations a.
Insoection Scoce (61726)
The inspectors observed all or portions of the following surveillance tests:
STP-O-73D-2 Charging Pump Performance Test STP-O-73 D-1 Charging Pump Performance Test STP-O-12-0 Control Room Ventilation System Monthly Test STP-O-11-1 ECCS Pump Room Ventilation System Monthly Test STP-O-738-1 Service Water Pump Quarterly Test STP-O-65T-1 Quarterly ECCS Valve Operability Test STP-O-73B-2 Service Water Pump Quarterly Test STP-O-73C-2 Component Cooling Water Pump Quarterly Surveillance STP-O-99-2 Wide Range Noble Gas Monitor Functional Test 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 pre-test briefings that included question and answer sessions attended by all test participants.
Calvert Cliffs and industry events associated with the testing were often discussed.
The test participants appeared knowledgeable of their assigned responsibilities and approved procedures were used. Engineering participation was clearly observed in the preparation for and conduct of the tests.
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The inspectors observed that discrepancies noted during the tests were properly entered into the BGE corrective action system. Radiological controls used during data gathering across contaminated area boundaries had improved over previous inspection observations following training of radiation controls, operations, and testing personnel.
The inspectors observed radiological controls technicians taking surveys and swipes to ensure contamination was controlled.
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Conclusions The surveillance testing performed during this inspection period was thorough, consistent with industry standards, and sufficient in scope to demonstrate that the subject equipment would perform their safe +t dunctions.
Ill. Enoineerina E1 Conduct of Engineering E1.1 Missing Part on Unit 1 Saltwater Strainer a.
Inspection Scope The inspectors reviewed the circumstances of a missing part on the Unit 1 saltwater strainer for the safety related service water heat exchangers, b.
Findinas and Observations On December 2,1998, BGE plant engineering personnelidentified that a part was missing from all four salt water strainers in the Unit I service water system.
Specifically, strainer basket guide rings were left out of the inlet flanges of the salt water strainers when the strainers were installed during the 1998 refueling outage.
BGE informed the inspectors that during the installation this item may have been inadvertently discarded. This missing part allowed a gap of approximately 1/4" to
%" wide to exist between the strrJner basket and the inlet of the strainer. Debris could bypass the strainer through the gap and flow directly to the plate and frame heat exchanger.
The inspectors noted that clogging of the strainers wdh debris had been a problem in recent months. When needed to ensure continued system operability, the clogging had been corrected by a number of unplanned heat axchanger cleanings. BGE stated that while the missing part likely contributed to the clogging, the extent flow debris bypassing the strainer was indeterminate.
Technical Specification 3.7.7 required two saltwater subsystems be operable in Modes 1-4. BGE performed an operability determination and concluded the system remained operable with the missing part. The operability determination was performed in accordance with BGE approved procedures and was complete and timely.
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l The deficiency was documented in the BGE corrective action program and was scheduled to be corrected in December. The original maintenance order that installed the strainers did not specifically mention installation of the basket guide ring. Instead, the work order generally described installation of the strainer in accordance with design drawings. The guide ring was depicted on the drawings. Failure to include an
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l acceptance criterion for installation of the guide ring was a violation of 10 CFR 50, Appendix B, Criterion V, which required appropriate acceptance criteria for determining l
that important activities were satisfactorily accomplished. However, the problem had j
been identified by BGE and documented in the BGE corrective action system. Further, the occurrence had not been willful and could not have been precluded by a similar violation in the last two years. The inspectors reviewed the occurrence using NRC l
Enforcement Guidance Memorandum 98-006 and determined that a non-cited violation I
was appropriate in accordance with NRC Enforcement Policy Vll.B.1. (NCV 50-
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317&318/98-11-01)
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Conclusions BGE identified that a part had been inadvertently not included in the installation of the j
saltwater strainers for the Unit 1 service water heat exchangers. The absence of this part allowed some strainer bypass flow and may have contributed to recent heat
exchanger clogging. BGE evaluation of the problem and corrective actions were prompt and appropriate.
E8 Miscellaneous Engineering issues E8.1 (Closed) Licensee Event Report 50-317&318/98-08: Reactor Protective System Technical Specification Error BGE identified through reviews of operating experience from other nuclear power plants, that there was a wording inconsistency between technical specifications and the Calvert Cliffs Updated Final Safety Analysis Report (UFSAR). The prob:em involved the definition of thermal power used in the technical specifications for reactor protection at low nuclear (neutron) power such as during reactor startup. In response to the issue, BGE submitted an exigent license amendment request to the NRC on October 16,1998. The change requested to allow " Thermal Power" to be replaced I
with " Nuclear Instrument (NI) Power" in applicable technical specifications. The l
request was approved by NRC on December 8. The issue was discussed with BGE l
supervisory personnel during the onsite inspection. The licensee event report was l
closed.
l E8.2 (Closed) Unresolved item 50-317&318/96-10-03: Old Design issues identified During a BGE Review This item was created to resolve UFSAR discrepancies identified by BGE activities in reviewing and updating the Updated Final Safety Analysis Report (UFSAR). The unresolved item noted that BGE had identified approximately 40 UFSAR issues and three issues were specifically mentioned. One other issue mentioned in the original l
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unresolved item that had been identified by the inspectors involved spent fuel pool l
ventilation supply fans being installed in the plant but not used. The inspectors were informed during this inspection that the supply fans could be used when there were no l
fuel handling activities, but that operation of the fans during fuel handling was precluded by the scope of BGE testing of spent fuel pool area ventilation and technical specification requirements to ensure that a measurable negative pressure with respect to atmosphere was maintained during fuel movements (Technical Specification 3.7.11.3). The specific item regarding spent fuel area ventilation was therefore not a violation of NRC requirements.
All of the other issues had been identified by BGE and entered into the BGE corrective action system. The inspectors verified that UFSAR updates were being processed at the time of this inspection. It was not likely that any of the issues reviewed by the inspectors would have been identified by routine BGE efforts such as surveillance testing. There was no willfulness evident in any of the discrepancies. The inspectors i
I observed during previous inspections that BGE has been active in reviewing and updating the Calvert Cliffs UFSAR curing the initial enforcement discretion period (See l
Inspection Report 50-317&318/98-80, Section E8.2). Failure to properly update the
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UFSAR as changes to the plant were made was a violation of 10 CFR 50.71(e).
l However, this violation was not cited in accordance with the NRC Enforcement PoF::y (NUREG-1600), Section Vll.B.1. (NCV 50 317&318/98-11-02) The unresolved item is closed.
IV. Plant SuDDort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Implementation of the Radioactive Liquid and Gaseous Effluent Control Program a.
Insoection Scooe (84750-01)
l The inspection consisted of: (1) tours of radioactive liquid and gaseous effluent
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pathways and BGE process facilities; (2) a review of radioactive liquid and gaseous
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effluent release permits; (3) a review of identified unplanned or unmonitored release l
pathways; (4) a review of selected chemistry procedures; and (5) a review of the BGE l
1997 Annual Effluent Report.
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Findinos and Observations l
Radioactive liquid and gaseous effluent discharge permits were complete and met the Technical Specification /Offsite Dose Calculation Manual (TS/ODCM) requirements for sampling and analyses at the frequencies and lower limits of detection established in the TS/ODCM.
Projected doses to the public were well below the Technical Specification (TS) limits.
The inspectors determined that there were no anomalous measurements, omissions or adverse trends contained in the 1997 Annual Radioactive Effluent Release Report.
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R1.2 General Exposure Controls a.
Insoection Scope The inspectors selectively reviewed external and internal exposure controls, and contamination controls during plant tours. in particular, the inspectors reviewed BGE's planning, preparation, and implementation of radiological controls for diving activities within the Unit 2 spent fuel pool. Also reviewed were the applied radiological controls for new fuel inspection activities. The inspectors attended pre-job briefings for diving activities, reviewed work in progress, reviewed applicable documentation, and interviewed cognizant persorinel.
The review was against requirements contained in applicable regulations and BGE procedures.
b.
Observations and Findinas l
i BGE performed effective planning and preparation for diving activities within the spent
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fuel pool. BGE established and implemented appropriate work control procedures, j
l provided detailed pre-job briefings of workers, and performed pre-dive and ongoing job
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l radiological surveys consistent with procedure guidance and industry practice. Remote i
i reading teledosimetry was used to perform realtime monitoring of diver accumulated l
radiation dose. Radiological controls were consistent with BGE's recently issued risk based radiological controls work planning process. BGE implemented High Radiation Areas controls for diving consistent with applicable NRC regulatory guidance, posted j
l the diver's access point to the pool as a Very High Radiation Area, and established l
controls to preclude access of the diver to unsurveyed and Very High Radiation Areas.
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Multiple cameras were used to view the diver and work locations. BGE temporarily suspended diving activities when anomalous elevated radiation levels were detected.
No significant exposure was sustained by the diver as of the end of the inspection period.
BGE established and implemented appropriate radiological controls for new reactor fuel inspection activities. BGE performed contamination and radiation surveys of fuel canisters and fuel prior to worker handling and inspection of the fuel.
Radiological survey instrumentation used for conducting surveys for diving and fuel inspection activities were within calibration and had been source checked.
Contaminated areas were properly posted and barricaded consistent with program procedures.
BGE implemented effeuue supervisory and management oversight of diving activities.
General Supervisors were involved in planning, preparation and oversight of the work activities.
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Conclusions BGE was effectively implementing its fundamental radiological controls requirements for external and internal exposure control and contamination control. Effective exposure controls were implemented during Unit 2 spent fuel pool diving and Unit 2 i
fuel inspection activities.
i R1.3 Changes a.
Inspection SepJ2A The inspectors reviewed selected programmatic and organizational changes since the previous inspection. Areas reviewed included organization and staffing, programmatic changes, and equipment changes. Radiation Protection Improvement Plan (RPIP)
progress and achievements were also reviewed.
The review was against information and commitments provided by BGE in its October 1,1998, response to an NRC Notice of Violation and Proposed imposition of j
Civil Penalty dated September 2,1998, and against information and commitments provided by BGE in its presentation to the NRC at a June 18,1998, Predecisional Enforcement Conference, as documented in a July 9,1998, Predecisional Enforcement
Conference Report.
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The inspectors reviewed work in progress, reviewed applicable documentation, and interviewed cognizant personnel relative to the information and commitments provided.
b.
Observations and Findinas BGE modified its RPIP to focus on five common weaknesses identified in its review of radiological controls problems. These were: application of radiation protection fundamentals; corrective action, self-assessment, and trending; oversight and managemer,t; radiological risk management; and behavior management. BGE established a dedicated RPIP team with a task leader and support staff for each of the five common weaknesses identified. Specific plans and areas for enhancement, relative to each common weakness, were incorporated into BGE's formal action item tracking program with specific dates identified for deliverables. The RPIP team was planning implementation of program improvements prior to the March 1999 Unit 2 refueling outage. The planning included appropriate training of personnel and designation of " stand down days" for training purposes.
BGE reorganized the radiological controls organization and at the time of the inspection was in the process of transitioning to the new organization. BGE was developing position descriptions and functional responsibilities and authorities for the affected positions within the new organization. BGE had also hired additional professionallevel radiological controls staff personne.
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BGE significantly modified its work plannmg and control program to incorporate l
identification and control of work from a radiological risk perspective. BGE was also l
revising additional program procedures to provide for enhanced controls of radiological l
work activities.
BGE modified its radiation work permit program to provide for improved instructions to workers. BGE was also revising numerous procedures to enhance oversight and radiological controls for risk significant work activities.
At the time of the inspection BGE was completing their review and revision of radiological controls procedures including the radiological controls job coverage procedure.
c.
Conclusions The Radiation Protection improvement Program was being effectively implemented.
The work planning and control program was modified to incorporate identification and control of work from a radiological risk perspective. A revised radiation protection organization was being implemented to improve oversight and control of activities, and functional position descriptions, including responsibilities and authorities, for affected positions were being updated. BGE was continuing to revise radiological controls procedures to provide for improved control and oversight of radiological work activities.
R1.4 Unit 2 Outage Planning and Preparation a.
Insoection Scoce The inspector celectively reviewed radiological controls planning and preparation for the upcoming Unit 2 outage. The inspector discussed outage preparation with cognizant personnel and observed activities to verify radiation protection planning.
b.
Observations and Findinos BGE significantly modified its work planning and control program to incorporate
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identification and control of work from a radiological risk perspective. BGE froze the outage scope in mid 1998 and had categorized a significant portion of the planned
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outage work relative to its radiological risk potential. The work was being planned commensurate with that risk. Outage scope changes were to receive management j
review prior to addition of new items to the outage schedule. A pre-outage plan was j
under development and lessons learned from previous outages were being incorporated into the planning process. BGE placed additional radiological controls personnel within the outage planning organization to enhance planning and preparation and provided those individuals specific training on its work planning and scheduling tools.
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Conclusions
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Enhanced planning and preparation, from s radiological risk basis, was on-going for the upcoming Unit 2 outage. The work scope was identified and enhanced controls were l
being established consistent with risk.
R2 Status of RP&C Facilities and Equipment t
R2.1 Calibration of Effluent / Process Radiation Monitoring Systems (RMS), Calibration of Flow Rate Measuring Devices, and Calibration of Hydrogen Monitors t
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a.
Insoection Scooe (84750)
The inspectors reviewed: the most recent calibration results for the following selected i
effluent / process / area RMS and flow rate measuring devices; a BGE self-assessment of
RMS; and the BGE RMS improvement plan.
j Radiation Monitorina Systems
o Liquid Radwaste Effluent Monito-(Common)
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e Steam Generator Blowdown Radiation Monitors (Units 1 and 2)
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o Main Steam Line Monitors (Units 1 and 2)
e Main / Plant Vents Noble Gas Monitors (Units 1 and 2)
e Main Steam Header Noble Gas Monitors (Units 1 and 2)
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e Wide Range Noble Gas Monitors (Units 1 and 2)
e Waste Gas Discharge Noble Gas Monitor (Common)
e Containment Purge Radiation Monitors (Units 1 and 2)
o Condenser Air Evacuators Discharge Monitors (Units 1 and 2)
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e Containment Area High Range Monitors (Units 1 and 2)
e Control Room Air Intake Radiation Monitor Calibration of Flow Rate Measurina Devices e
Liquid Radwaste Effluent Line Flow Rate Measuring Device e
Steam Generator Blowdown Line Flow Rate Measuring Device e
Waste Gas Effluent System Flow Rate Measuring Device Channel Calibrations of Hvdroaen Monitors (TS 3/4.6.5)
The inspectors reviewed the most recent channel calibration results for the hydrogen monitors (for both units).
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b.
Findinas and Observations Electronic alignment results for the above RMS and flow rate indicators were found to be within the BGE's acceptance criteria. Radiological calibration methodology for the above RMS was acceptable. Linearity tests were appropriate. Secondary calibrations validated primary calibrations.
BGE identified certain RMS as warranting additional attention in accordance with their maintenance rule program. Action plans have been developed to improve system performance. BGE calibration of hydrogen detectors met vendor recommendations.
c.
Conclusions BGE established, implemented, and maintained an effective program for radiation monitoring system calibrations, including trending and tracking of system reliability.
R2.2 (Closed) Unresolved items 50-317&318/97-04-02 and 03; Air Cleaning Systems a.
Insoection Scoce The inspection evaluated charcoal testing and included a review of BGE surveillance test results for the plant effluent systems. The surveillances included visual inspection, in-place HEPA and charcoal leak tests, air capacity tests, pressure drop tests, and laboratory tests for the iodino collection efficiencies for effluent streams.
The inspected systems included:
Control Room Emergency Air Supply Systems;
Spent Fuel Handling Building; Penetration Room Exhaust System;
e Containment Building;
ECCS Pump Room Exhaust System; and e
Auxiliary Building Ventilation Charcoal Filters.
b.
Findinas and Observations The inspector found that deficiencies identified by BGE during surveillance testing for l
the above systems were entered into the BGE corrective action system and corrected.
The as left conditions for each of the systems met BGE acceptance criteria and there
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l were no problems identified with any of the tests reviewed.
The two unresolved items involved apparent discrepancies of the BGE charcoal testing methodology with the industry standards required in technical specifications.
Unresolved item (URI 50-317&318/97-04-02) involved the allowable range of air flow used during charcoal acceptance testing. This item was found to be not a violation of l
NRC requirements because the test flow used in BGE testing was within the tolerance
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allowed in applicable industry standards. Unresolved item (URI 50-317&318/97-04-l 03) involved use of methyl-iodide as a test reagent instead of iodine as discussed in l
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t the ASTM standard for charcoal testing. The inspector found that this discrepancy was of minor significance because the use of methyliodide challenge agent was an acceptable and more conservative agent for demonstrating removal efficiency of
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charcoal. BGE had conducted testing using iodide as the challenge agent as a demonstration of effectiveness. Both unresolved items were closed.
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c.
Conclusions I
BGE established, implemented, and maintained an effective ventilation system surveillance program with respect to charcoal adsorption surveillance tests, HEPA mechanical efficiency tests, and air flow rate tests.
R3 RP&C Procedures and Documentation R3.1 Radiation Safety Surveillance Documentation a.
insoection Scope (71750)
i The inspectors reviewed radiation protection administrative controls associated with-the performance of portal monitor and RM-14 frisker instrument source checks. The i
inspectors reviewed the completed data tables associated with BGE procedures RSP 1-126, " Pre-Operational Checks of Portal Monitors", RSP 1-121, " Radioactive Source Control", and RSP 1-102, " Pre-Operational Checks of Portable Survey Instruments".
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Observations and Findinag Daily operational checks of portal monitors and portable survey instruments were required by BGE procedures. The checks were performed using a radioactive source to ensure that the monitors were working as designed. Radiation protection technicians were responsible for performing the checks in accordance with radiation safety procedures. The results of the checks were documented by the technicians on
surveillance data sheets that accompany the procedures, then checked by principal radiation safety technicians.
The inspectors identified a number of documentation problems in some of the data sheets. For example, on November 8 and 9, the technician did not sign the source check-out log for receipt of the radioactive source used to complete the instrument checks. On November 16 and 17 and 20, technicians did not indicate on the data sheets that a catisfactory check of the PCM-1 detectors had been completed for a single detector prior to testing the next detector. On November 27, source check data sheets were not reviewed by the supervisor after the checks were completed. In some cases, technicians were using a line to designate that multiple steps had been completed instead of individually marking each block as the step was done. BGE procedure PR-1-103. "Use of Procedures," required that the data block for each step L
be completed before continuing to the next step. Also, supervisors were required to l
ensure that self-verification techniques were used in completing the surveillances. The l
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inspectors considered that use of continuous lines through multiple check data sheets was not a self-verification technique.
The inspector's findings were discussed with radiation protection supervisory personnel. The supervisors agreed with the inspector findings and informed the inspector that problems with documentation had been identified by BGE and corrective actions were being implemented. These corrective actions included training to technical staff, clarification and improvement of procedures, and more careful supervisory oversight of activities. Additionally, a wide range of improvement plans were being implemented to correct radiation department weaknesses. As such, the failure to document surveillance results and supervisory reviews in accordance with BGE procedure PR-1-103 was a non-cited violation in accordance with the NRC Enforcement Policy section Vll.B.1 and Enforcement Guidance Memorandum 98-6.
(NCV 50-317&318/98-11-03)
c.
Conclusions BGE radiation protection technicians (RST) and supervisors exhibited poor surveillance documentation practices for some daily radiation monitoring source checks. This problem had been previously identified by BGE and entered into their corrective action program. Corrective actions were being implemented.
R7 Quality Assurance (QA) in RP&C Activities R7.1 Review of Quality Assurance Activities a.
Insoection Scoce (84750)
l The inspection consisted of a discussion of 1996 chemistry audit responses with appropriate BGE staff, a review of QA policy of the BGE measurement laboratory, and a review of implementation of :he measurement laboratory QC program for radioactive liquid and gaseous effluent samples.
b.
Findinas and Observations All inter-laboratory quality assurance measurement comparisons were within BGE acceptance criteria. No anomalous trends were noted during a review of quality control charts for gamma and tritium measurements.
The BGE quality assurance audit team members identified no discrepancies of regulatory significance. Responses to audit findings were reasonable.
c.
Conclusions BGE established, implemented, and maintained an effective program with respect to
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response to audit findings and quality control for validating measurement results for l
radioactive effluent samples.
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R8 Miscellaneous RP&C lssues R8.1 Planning and Preparation For Steam Generator Replacement a.
Inspection Scoce The inspectors selectively reviewed BGE radiological controls planning and preparation for steam generator replacement. The BGE schedule provides for replacement of Unit 1 steam generators in March 2002. The inspectors reviewed work in progress, reviewed applicable documentation, and interviewed cognizant personnel relative to replacement activities.
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Observations and Findinas i
BGE was actively planning for replacement of steam generators at Calvert Cliffs Units 1 and 2. BGE established a project organization, developed project milestones, developed a design specification for the generators, and developed, among other items, a delivery schedule. BGE was reviewing industry experience for replacement of steam generators. BGE was developing a project plan and had developed a division of work scope between itself and its contractor. Dedicated radiation safety personnel were assigned to the team to provide for review, evaluation and recommendations in the area of radiological controls, including ALARA controls, c.
Conclusions i
BGE was performing appropriate radiological controls planning and preparation for replacement of steam generators.
R8.2 Corrective Actions For April 9,1998, Reactor Vessel Annulus Problem a.
Insoection Scoce On September 2,1998, the NRC issued a Notice of Violation and Proposed Imposition of Civil Penalty, to BGE for radiological controls problems encountered during work in the Unit 1 reactor vessel annulus on April 9,1998. The inspectors reviewed the implementation of BGE's corrective actions associated with this matter as outlined in its October 1,1998, response. The inspectors also reviewed implementation of BGE commitments documented in the NRC Predecisional Enforcement Conference Report dated July 9,1998.
b.
Observations and Findinos b.1 (Closed) VIO (EA 98-280-010131: BGE did not implement radiation protection procedures for use of alarming dosimeters, recording of dosimetry data, and verification of personnel use of dosimetry as required by radiation protection program procedure BGE implemented the corrective and preventive actions for this violation as outlined in its October 1,1998, response to the NRC's Notice of Violation and Proposed imposition of Civil Penalty dated September 2,1998. The actions included immediate, short term, and long term actions as described in its letter.
b.2 (Closed) VIO (EA 98-280-01023): BGE did not implement radiation protection procedures for setting of dosimetry alarms, documentation of use of dosimetry, and response to dosimetry alarms.
BGE implemented the corrective and preventive actions for this violation as outlined in its October 1,1998, response to the NRC's Notice of Violation and Proposed Imposition of Civil Penalty dated September 2,1998. The actions included immediate, short term, and long term actions as described in its letter.
b.3 (Closed) VIO (EA 98-280-01033): BGE did not properly calculate stay times for personnel entering high radiation areas as required by procedures.
BGE implemented the corrective and preventivre actions for this violation as outlined in its October 1,1998, response to the NRC's Notice of Violation and Proposed imposition of Civil Penalty dated September 2,1998. The actions included immediate, short term, and long term actions as described in its letter.
b.4 (Closed) (eel 50-317/98-05-01 a): Radiation safety personnel did not implement procedures and properly calculate staytime for workers in high radiation areas. This item was subsequently identified as one example of failure to follow procedures and was cited as a violation (EA 98-280-01033). This item is closed for administrative purposes.
b.5 (Closed) (eel 50-317/98-Q 5-01 b1: Radiation safety personnel did not provide prescribed dosimetry to workers. This item was subsequently identified as one example of failure to follcav procedures and was cited as a violation (EA 98-280-01013), (See Section b.1 above.) This item is closed for administrative purposes.
b.6 (Closed) (eel 50-317/98-Q5-01 c): Radiation safety personnel did not implement staytime procedures for uorkers in high radiation areas. This item was subsequently identified as one example of failure to follow proceourcs and was cited as a violation (EA 98-280-01033). (See Section b.3 above.) This item is closed for administrative purposes, b.7 (Closed) (eel 50-317/98 05-01d): Radiation safety personnel did not properly set alarms for workers in high radiation areas. This item was subsequently identified as one example of failure to follow procedures and was cited as a violatinn (EA 98-280-01023). (See Section b.3 above.) This item is closed for administrative purposes.
b.8 (Closed) (eel 50-317/9005-01e): Radiation safety personnel did not implement procedures for documentation of alarming dosimeter data for workers in high radiation areas. This item was subsequently identified as one example of failure to follow
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procedures and was cited as a violation (EA 98-280-01013). (See Section b.1 above.)
l This item is closed for administrative purposes.
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b.9 (Closed) (eel 50-317/98-05-01f): Radiation safety personnel did not instruct a worker f
in a high radiation area to exit the area when his dosimeter alarmed. This item was subsequently identified as one example of failure to follow procedures and was cited as a violation (EA 98-280-01023). (See Section b.2 above.) This item is closed for edministrative purposes.
I b.10 (Closed) (eel 50-317/98-05-01a): Radiation safety personnel did not properly monitor j
radiation dose, dose rate and staytime for a worker in a high radiation area. This item was subsequently identified as one example of failure to follow procedures and was cited as a violation (EA 98-280-01023). (See Section b.2 above.) This item is closed for administrative purposes.
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b.11 (Closed) (eel 50-317/98-05-01h): Radiation safety personnel did not properly document issuance of dosimetry. This item was subsequently identified as one example of failure to follow procedures and was cited as a violation (EA 98-280-01023). (See Section b.2 above.) This item is closed for administrative purposes.
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Conclusion Corrective and preventive actions documented in BGE's October 1,1998, response to an NRC Notice of Violation and Proposed imposition of Civil Penalty dated September 2,1998, were implemented, as were commitments outlined in an NRC Predecisional Enforcement Conference Report dated July 9,1998.
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P8 Miscellaneous EP lasues l
P8.1 Emergency Action Levels Annual Review (IP 71750)
l On December 11, the inspectors observed a briefing that BGE emergency planning personnel provided to state and local government officials and emergency operations
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l center directors. All affected state and local governments were represented. BGE i
personnel provided a current assessment of the emergency planning program as well as their vision and goals for the future. BGE personnel reviewed their processes and
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procedures for determining emergency action levels, making protective action j
l recommendations, and severe accident management strategies. The review allowed participation by the attendees. BGE Nuclear Performance Assessment Department personnel attended the review to assess the adequacy of BGE's interface with state and local government officials. The inspectors concluded that presentation provided by l
l BGE was acceptable and met the training expectations spacified in the BGE emergency response plan implementing procedure (ERPIP)-904, " Emergency Response Training."
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V. Management Meetings
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t X1 Exit Meeting Summary
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During this inspection, periodic meetings were held with station management to l
discuss inspection observations and findings. On December 28,1998, an exit meeting
was held to summarize the results of the inspection. BGE management in attendance
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acknowledged the findings presented.
X2 Probabilistic Risk Assessment Meeting Summary
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On November 19,1998, two NRC Senior Reactor Ana!ysis (SRAs) met with BGE reliability engineering personnel to discuss risk assessment. The visit included a review of Calvert Cliffs probabilistic risk assessment model, plant configuration, and use of risk in plant activities.
X3 Management Meeting Summary On December 1 and 2,1998, Mr. Hubert Miller, Region 1 Administrator, and others of
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NRC Region I toured Calvert Cliffs and met with various ir.dividuals. Topics of j
discussion included general plant performance and general license renewal activities.
On December 10,1998, Mr. John White, Chief, Radiation Safety Branch, Division of Reactor Safety, NRC Region I, met with BGE representatives to discuss its Radiation Protection improvement Plan (RPIP). The meeting included discussion of organizational changes, procedure development, personnel training, and enhanced radiological controls practices.
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ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED B.GE C. Cruse, Vice President - Nuclear Energy Division P. Katz, Plant General Manager K. Cellars, Manager, Nuclear Engineering L. Wechbaugh, Superintendent, Nuclear Maintenance M. Navin, Superintendent, Nuclear Operations B. Montgomery, Director, Nuclear Regulatory Matters S. Sanders, General Supervisor, Radiation Safety T. Sydnor, General Supervisor, Plant Engineering D. Holm, General Supervisor, Plant Operations T. Pritchett, Superintendent, Technical Support L. Smialek, Radiation Protection Manager J. Lemons, Manager, Nuc! ear Support Services Department A. Edwards, Director Nuclear Security T, Forgette, Director, Emergency Planning Unit State and Local Government Officials R. McLean, Administrator, Nuclear Evaluations, Maryland Department of Natural Resources D. Hall, Calvert County Emergency Management P. Cooper, St. Mary's County Emergency Management W. Hodges, Maryland Department of Natural Resources NBC
~J. White, Chief, Radiation Protection Branch, DRS, Region I H. Miller, Regional Administrator, Region i G. Meyer, Chief, Civil, Mechanical and Materials Engineering Branch, DRS, Region 1 J. Trapp, Senior Reactor Analyst, DRS, Region 1 J. Shediosky, Senior Reactor Analyst, DRS, Region 1 INSPECTION PROCEDURES USED IP 71707 Plant Operations IP 62707 Maintenance Observation IP 61726 Surveillance Observation IP 92700:
Onsite Follow up of Written Reports at Power Reactor Facilities IP 72755:
Inservice inspection - Data Review and Evaluation IP 37551:
Onsite Engineering IP 71750:
Plant Support Activities IP 83720:
Occupational Exposure IP 92904:
Follow-up - Plant Support IP 81700:
Physical Security Program for Power Reactors IP 92903:
Miscellaneous Engineering IP 92902:
Miscellaneous Maintenance
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Attachment 1
LIST OF ACRONYMS USED ALARA As Low As is Reasonably Achievable
'CVCS-Charging and Volume Control System EA Enforcement Action (NRC)
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' Escalated Enforcement item (NRC) -
~ ERPIP Emergency Response Plan Implementing Procedure HEPA High Efficiency Particulate Air filter INPO Institute of Nuclear Power Operations LOCl Loss of Coolant incident NI Nuclear instrument NPO Nuclear (non-licensed) Plant Operator PDR Public Document Room
.QA.
Quality Assurance
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RMS Radiation Monitoring System i
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RST'
Radiation Safety Technician SRA,
Senior Reactor Analyst TS
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-Technical Specification TS/ODCM
- Technical Specification /Offsite Dose Calculation Manual UFSAR-Updated Final Safety Analysis Report URI -
Unresolved item (NRC)
ITEMS OPENED, CLOSED, AND DISCUSSED
' Opened and Closed 50-317&318/98 11-01 NCV Failure to have adequate acceptance criteria to ensure that a safety related modification was installed in accordance
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with approved drawings 50-317&318/98-11-02 NCV Failure to place updated information in the UFSAR j
. 50-317&318/98-11-03-NCV L Failure to follow administrative procedures for radiation safety source checks i
Closed 50-317&318/97-04-02 URI Charcoal testing requirements; Velocity too high i
50-317&318/97-04-03 URI- ' Charcoal testing requirements; Removal efficiency does not use elemental iodine l
.EA 98-280-01013; VIO BGE did not implement radiation protection procedures for use of alarming dosimeters, recording of dosimetry data, and verification of personnel use of dosimetry as required
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by radiation protection program procedures.
' EA 98-280-01023 <
,VIO -. BGE did not implement radiation protection procedures for setting of dosimetry alarms, documentation of use of dosimetry, and response to dosimetry alarms.
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Attcchment 1
EA 98-280-01033:
VIO BGE did not properly calculate staytimes for personnel entering high radiation areas as required by procedures.
50-317/98-05-01 a eel Radiation safety personnel did not implement procedures and properly calculate staytime for workers in high radiation areas.
50-317/98-05-01 b eel Radiation safety personnel did not provide prescribed dosimetry to workers.
50-317/98-05-01c eel Radiation safety personnel did not implement staytime procedures for workers in high radiation areas.
50-317/98-05-01d eel Radiation safety personnel did not properly set alarms for workers in high radiation areas.
50-317/98-05-01 e eel Radiation safety personnel did not implement procedures for documentation of alarming dosimeter data for workers in high radiation areas.
50-317/98-05-01f eel Radiation safety personnel did not instruct a worker in a high radiation area to exit the area when his dosimeter alarmed.
50-317/98-05-01g eel Radiation safety personnel did not properly monitor radiation dose, dose rate and stay time for a worker in a high radiation area.
50-317/98-05-01h eel Radiation safety personnel did not properly document issuance of dosimetry.
Discussed items None
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