ML20141D934

Radiation Safety Procedure 1-104, Area Posting & Barricading & High Radiation Area Pre-Entry Checklist

ML20141D934
Person / Time
Site:	Calvert Cliffs
Issue date:	05/09/1997
From:	BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20141D917	List: ML20141D914 ML20141D934
References
RSP-1-104, NUDOCS 9705200242
Download: ML20141D934 (10)

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1 ATTACHMENT (3) ,

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1 RADIATION SAFETY PROCEDURE 1-104,

" AREA POSTING AND BARRICADING,"

l. ATTACHMENT (8), ,

"HIGH RADIATION AREA PR.E-ENTRY CHECKLIST" 4

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9705200242 970509 I PDR ADOCK 05000310 S PDR .

t Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant May 9,1997

RSP 1-104 Rn. 10 AREA POSTING AND BARRICADING Page 41 of 42 RAD SAFETY ATTACHMENT (8)

HIGH RADIATION AREA PRE-ENTRY CHECKLIST V PHYSICALLY VERIFY PRIOR TO FNTRY that individual (s) are properly wearing all required dosimetry (TLD/EPD or Specials).

V PHYSICALLY VERIFYthat the worker's HP ID number appears on the EPD display, when the button is pressed.

. IFpersonnel are to be wearing Special Dosimetry AND EPDs are not part of the 8 package, THEN VERIFYthat the person has the appropriate Special Dosimetry 6 PER the SWP requirements.

4 f_H. YSICALLYVERIFY THAT all additionally dosimetry or monitoring devices or a combination of both required by the SWP (for example, Specials, SAIC) are present and worn correctly.

V VERIFY PRIOR TO ENTRY that the SWP authorizes the individual (s) to enter the area and perform the assigned task.

4 VERIFY PRIOR TO ENTRY by either viewing the record -(or copy of the initial Pre-Job Briefing Attendance Record (RSP 1-106-1 or RSP 1-106-2 Update Record) or by phone conversation with the RCSS and SWPC, that the individual (s) have signed the briefing C sheet.  ?

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4 VERIFY PRIOR TO ENTRY that the individual (s) understand the SWP, dose rate limits, stay limits, stay times, and when to read EPD/DRDs.

4 VERIFY PRIOR TO ENTRYthat the individual (s) understand the locations of HRA hazards and HPA boundary / barricade locations.

4 VERIFYPRIOR TO ENTRYthat the individual (s) understand the RST coverage being ,

I provided (for example, continuous remote, direct, etc.), and how the RST plans to communicate job coverage data.

4 IF SA/C TELEMETRY SYSTEM IS USED, then verify that the monitoring station is receiving the SAIC signal.

V VERIFY PRIOR TO ENTRY that the individual (s) understand all RST special instructions )

or" Hold Points." l j

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ATTACHMENT (4) h RADIATION SAFETY PROCEDURE 1-104, ATTACHMENT (9), "ALL RADIOLOGICAL CONTROLLED AREA (RCA) ENTRANCE POINTS / CONTAINMENT ACCESS

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VERIFICATION' CHECKLIST" i

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I Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant  !

May 9,1997 I

l RSP 1-104 ,

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AREA POSTING AND BARRICADING Pag. 42 of 42 l

RAD SAFETY ATTACHMENT (9)

ALL RCA ENTRANCE POINTS / CONTAINMENT ACCESS VERIFICATION CHECKLIST N01E:

For allpersarmel. Radiation Safety makes routine verification checks at the K-Line. Containment Access, andprior to entry to a fligh Radiation Area. The esception to this rule arepersormel(for example, Operations Chemistry, Security. Radiac instrument repairers, emd Radiation Safetypersonnel) who make multiple entries into RCAs pursk the Auxiliary Buildmg K-Line entrance. In this cirrumstance, an RST vergfles the prvperplacement ofdosimetry (ILD and EPD), HP ID numberin the EPD, and SilP istformation only the times the individual (s) Interface (s) with an Access Contml Il'ork Station (typically, the beginning ofship).

All, RCA ENTibtNCEPOIN7S 4 ASK the uvrker which SHP Activity they are signed in on and VERIYY that they knme their Jose and dose rate T

limits.

4 VilYSICALLY VERIFY the uvrker is wearing their EPlWTLD or Special Dosimetry PER the SHP requirements.  ? $

e T N PilYSICALLY VERIFY that the uvrker's llP ID number appears on the EPD display when the button is pressed, if applicable.

N01E:

For Aux Bldg access, the EPLYlLD should be wom within a hands distance apart and on thefront part of the baly above the belt.

CONDiINMENTACCESS CON 1ROL 3

4 ASK the uvrker which SWP Activity they are signed in on and VERIFY that they knmv their dose and dose rate limits. 9 O

4 PilYSlCALLV. VERIFY the uvrker is wearing their EPlWTLD or Special Dosimetry PER SHP o requirements, c e-4 PilYSICALLY VERIFY that the swrker's llP ID number appears on the EPD di. splay when the button is pressed, if applicable.

4 PliYSICALLY VERIFY that the uvrker's EPD Dose Limit agrees with their SHP Activity Dose Limit, if applicable.

NOTE:

. For CTAIT Acau, thf EPD should be worn in thefront pocket of the anti-Cs with the velcrvJ1ap secured or taped. The TLD $

should be norn inside t)> snti-Cs on thefmnt part of the balv above the belt and should be hwated in a position such that ut y willnot be shiclJedby thQrk Q

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4 IMMEDIATE ACTIONS TAKEN FOLLOWING THE INADVERTENT HIGH RADIATION AREA i

ENTRY EVENT ON MAY 4,1997 i

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Baltimore Gas and Electric Company Calvert Cliffs Nuclear P.* rer Plant May 9,1997 l

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. ATTACHMENT (5) ,

' IMMEDIATE ACTIONS TAKEN FOLLOWING THE INADVERTENT HIGH RADIATION AREA ENTRY EVENT ON MAY 4,1997 A.

SUMMARY

OF EVENT  ;

On May 4,1997, at approximately 1:04 p.m., during the construction of the third tier of a scaffold platform in the overhead of No.11 Reactor Coolant Waste Monitor Tank Room in the Auxiliary Building, two contractor workers were allowed to access an un-surveyed High Radiation Area (HRA).

The contractor health physics (ilP) technician covering the work had not performed the required surveys during the scaffold construction. Subsequent surveys identified a maximum dose rate of approximately 300 mrem / hour near one end of the platform. One worker received a dose of approximately 3.9 mrem by electronic personal dosimeter (EPD), while the other worker received a dose of approximately 6.2 mrem  ;

(by EPD) With their EPDs set to alarm at a dose rate of 99 mrem / hour, one worker's peak recorded  ;

dose rate (by EPD) was 141 mrem / hour while the other worker's peak dose rate was 157 mrem / hour (by EPD). Upon receipt of their dose rate alarms, the workers exited the scaffold and promptly notified ,

Radiation Safety personnel.

H. IMMrnlATE ACTIONS TAKEN '

o Workers (contractor employees) were removed from the Radiologically Controlled Area (RCA).

o Worker's access to the RCA was suspended and a dose assessment of the event was initiated.

o immediate survey of the work location (top platform of scaffold) revealed a dose rate .

> 100 mrem / hour. The work area was secured and posted as a HRA. A backup survey identified a maximum dose rate of 300 mrem / hour at one end of the top platform on the scaffold.

l o Plant General Manager stopped all work inside the RCA, with exception of work necessary to support safe operation of Unit 1.

o Preliminary interviews were conducted with personnel directly involved in the event.

o An Issue Report was initiated documenting the event and recommending actions to resolve the issue.

o Commenced a Human Performance Enhancement System evaluation root cause analysis, o Electronic personal dosimeter alarm setpoint limits were changed to 80 mrem / hour or less for non-HRA work permits.

=> Nuclear Regulatory Commission Senior Resident inspector was briefed on the event. l c Verified scaffold workers involved in the event were properly logged in under correct Special Work Permit.

= A training evaluation confirmed that the contractor llP technician involved in the event was i provided with the knowledge and skills required to perform his duties, including the requirement ,

to conduct surveys during scaffold construction.  ;

=> Results of a survey conducted on April 21,1997 noted a dose rate of 20-30 mrem / hour in the i overhead of No. I1 Reactor Coolant Waste Monitor Tank Room following a planned ion exchanger resin transfer to the spent resin metering tank. The results were documented in the job coverage record, however, it was not pursued because the pipe is inaccessible in the overhead. An I informational posting has been put in place identifying this section of the pipe as a potential source I of high radiation.

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- ATTACHMENT (5)

' IMMEDIATE ACTIONS TAKEN FOLLOWING THE INADVERTENT HIGH RADIATION AREA ENTRY EVENT ON MAY 4,1997

=> The General Supervisor-Radiation Safety implemented controls for the restart of work in the RCA in a memorandum to Radiation Safety supervision, and briefed the appropriate Radiation Safety personnel on these controls, the event, and conservative decision making. With these controls in place and necessary briefings conducted, the Plant General Manager authorized resumption of limited work in the RCA.

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ATTACHMENT (6)

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i INTERIM CORRECTIVE ACTIONS  ;

IMPLEMENTED FOR CONTROL OF WORK '

IN RADIOLOGICALLY CONTROLLED AREAS l

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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant May 9,1997

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, A'ITACHMENT (6)

INTERIM CORRECTIVE ACTIONS IMPLEMENTED FOR CONTROL OF WORK IN RADIOLOGICALLY CONTROLLED AREAS ,

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A. The General Supervisor-Radiation Safety directed, in a memorandum to Radiation Safety supervision, implementation of the following radiation control instructions as interim corrective actions effective May 6,1997:

1. For Non-fligh Radiation Area Work (NO ENTRY TO OVERHEAD AREASh

a. For Routine Access to Auxiliary Building (NO WORK): (tours, inspections, etc.)

1. Radiation Safety Supervisor / Principal Radiation Safety Technicians will review thejob and Special Work Permit (SWP) requirements with the individual.

2. The individual will check in with the Auxiliary Building Level Technician, who -

will provide coverage as needed. i

b. For Routine Access to Auxiliarv Building (IIANDS ON WORKh ,

1. Radiation Safety Supervisor / Principal Radiation Safety Technicians will review thejob and SWP requirements with the workers.

2. Issue a job coverage record, which includes special instructions, procedure referrals, and recent survey information, as appropriate.

3. Radiation Safety or Bartlett Technicians will provide job coverage per the SWP and the job coverage record. The Auxiliary Building Level Technician will provide coverage verification.

C. For Containment Work:

1. Radiation Safety Supervisor / Principal Radiation Safety Technicians will review f thejob and SWP requirements with the workers.

2. Issue a job coverage record, which includes special instructions, procedure ,

referrals, and recent survey information, as appropriate.

3. Radiation Safety or Bartlett Technicians will provide job coverage per the SWP and the job coverage record. A two-member team of Rover Technicians will provide coverage verification.

2. For High Radiation Area or Overhead Work in the RCA:

a. Radiation Safety Supervisor / Principal Radiation Safety Technicians will review the job and SWP requirements, and either conduct or be present for SWP briefings.

b. Issue a job coverage record which includes special instructions, procedure referrals, and recent survey information, as appropriate.

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' INTERIM CORRECTIVE Af TIONS IMPLEMENTED FOR CONTROL OF WORK IN RADIOLOGICALLY CONTROLLED AREAS j

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c. As a minimum, a two-member team consisting of Radiation Safety or Bartlett  !

Technicians will provide job coverage per the SWP and job coverage record. A j Princ'ipal Radiation Safety Technician will provide supervision of job coverage l activities and may be a member of the two-member team.  ;

3. A BGE Radiation Safety Technician will be designated as the Unit 1 Shift Technician -

responsible for Unit i Operations.

4.' Radiation Safety supervision (on-shift) will provide face-to-face turnover on jobs in progress.

I B. The Plant General Manager has directed the establishment of an Independent Review Team, headed by the Chairman of our Plant Operations and Safety Review Committee, to identify limiting weaknesses in the Radiation Safety Program, assess the etTectiveness of the interim corrective actions initiated by Radiation Safety, and recommend to the Plant General Manager any additional actions or controls that need to be taken for work in Radiologically Controlled Areas.

In addition, the Plant General Manager has directed the Nuclear Performance Assessment Department to conduct a titorough audit and review of Radiation Safety to identify any programmatic concerns. This will include, but may not be limited to, a review and audit of the following Radiation Safety items: procedures, access controls and supervisory oversight, high radiation controls, surveys (technique and actions taken based upon survey results), job coverage, the permit process (SWPs, etc.), special activities (such as duties, responsibilities, and controls during diving evolutions), human performance issues, and training. These items will be reviewed and identified as short-term or long-term items to be addressed accordingly. The Plant General Manager has directed the Independent Review leam to evaluate and provide input to the audit plan.

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