ML20148R979
| ML20148R979 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/01/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20148R934 | List: |
| References | |
| 50-317-97-03, 50-317-97-3, 50-318-97-03, 50-318-97-3, NUDOCS 9707080062 | |
| Download: ML20148R979 (32) | |
See also: IR 05000317/1997003
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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License Nos.
DPR-53/DPR-69
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Report Nos.
50-317/97-03; 50-318/97-03
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Licensee:
Baltimore Gas and Electric Company
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Post Office Box 1475
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Baltimore, Maryland 21203
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Facility:
Calvert Cliffs Nuclear Power Plant, Units 1 and 2
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Location:
. Lusby, Maryland
Dates:
April 13,1997 through May 31,1997
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Inspectors:
J. Scott Stewart, Senior Resident inspector
Fred L. Bower lli, Resident inspector
Henry K. Lathrop, Resident inspector
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Leonard J. Prividy, Senior Engineer, DRS
Jason Jang, Senior Radiation Specialist, DRS
Lonnie Eckert, Radiation Specialist, DRS
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Approved by:
Lawrence T. Doerflein, Chief
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Projects Branch 1
Division of Reactor Projects
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9707080062 970701
ADOCK 05000317
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EXECUTIVE SUMMARY
Calvert Cliffs Nuclear Power Plant, Units 1 and 2
Inspection Report Nos. 50-317/97-03 and 50-318/97-03
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 radioactive effluents and engineering.
Plant Operations
BGE identified that the 12 HPSI pump handswitch had been misaligned following
troubleshooting. This event was the third control switch mispositioning in the last year
that was not identified during initial shift turnover control board walkdowns. BGE
management indicated that actions were being taken to improve problem identification
during control board walkdowns.
The inspectors observed that the startup from the Unit 2 refueling outage was conducted
with a strong regard for nuclear safety. Good management oversight, pre-evolution briefs,
and excellent communications were evident during the startup and testing programs.
During a plant walkthrough, the inspectors identified that a lock on the suction isolation
valve for 11 auxiliary feedwater pump was configured so that the lock and chain could be
easily removed without need of the key. In response, BGE documented the problem and
conducted walkdowns of locked components throughout the plant to verify there were no
additional problems. The inspectors considered the problem to be an isolated occurrence
and the BGE response appropriate to the circumstances.
The inspectors observed the BGE response to a Unit 1 reactor coolant leak and found the
activities effective in diagnosing and mitigating the event. The plant shutdown was well
controlled and the leak was quickly isolated. Support activities including engineering,
radiation protection, and maintenance were excellent and ensured that there were no
complications during the event.
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Maintenance
The implementation of the warehouse management system contributed to the reduction in
the delivery of incorrect or defective parts to maintenance job sites. One practice of re-
issuing parts returned from the field without a thorough inspection was weak and had the
potential to introduce degraded or defective parts in safety-related applications.
Enaineerina
Changing conditions, such as the fouling factors and fouling rates have continued to
challenge the operability of the service water system. The inspectors concluded that BGE
continues to be proactive in testing and engineering work related to the service water
system reliability. Until the scheduled replacement of the service water heat exchangers in
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Executive Summary (cont'd)
1998 (Unit 1) and 1999 (Unit 2), this proactive approach appeared commensurate with the
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safety significance of the system.
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Plant Suonort
BGE maintained and implemented a very good radioactive liquid and gaseous effluent
control program. Also, BGE implemented a good routine surveillance test program for plant
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effluents.
Safety Assessment
A BGE effluent control program quality assurance audit was sufficient to effectively assess
the program. BGE implemented a very good quality control program to validate
measurement results for effluent samples.
The inspector found that the radiation protection department did not generate issue reports
for some worker concerns. The BGE practice of using gold cards to document some
procedure compliance and personnel safety concerns was considered poor and could
prevent timely resolution of the concern.
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TABLE OF CONTENTS
EX ECUTI VE S U M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . il
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TAB L E O F CO NT ENT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
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Summ a ry of Pla nt Statu s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1. O p e r a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
01
Conduct of Operatio ns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
01.1 General Comments
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01.2 12 HPSI Pump Handswitch Mispositioning . . . . . . . . . . . . . . . . . 2
01.3 Reactor Coolant Leak on Unit 1
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Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . 4
02.1 Engineered Safety Feature System Walkdown
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11. M a i nt e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
M1
Conduct of Maintenance
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M 1.1 Routine Maintenance Observations . . . . . . . . . . . . . . . . . . . . . . 4
M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . -. . . . . . 4
M1.3 Worker injured During Maintenance . . . . . . . . . . . . . . . . . . . . . . 5
M 1.4 Procurem e nt Prog ram . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
M8
Miscellaneous Maintenance issues
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M8.1 (Closed) LER 50-317/9 6-04-00 . . . . . . . . . . . . . . . . . . . . . . . . . 7
M8.2 (Closed) LER 050-317/96-03
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111. Engineering
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E2
Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . 8
E2.1
(Update) URI 50-317 &318/9 6-06-03 . . . . . . . . . . . . . . . . . . . . . 8
E8
Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
E8.1
(Closed) Unresolved item 50-317&318/94-24-02 . . . . . . . . . . . 10
I V . Pl a n t S u p p o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
R1
Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . 12
R1.1 Implementation of the Radioactive Liquid and Gaseous Effluent
Control Program s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
R1.2 Implementation of the Effluent ALARA Program . . . . . . . . . . . . 13
R1.3 High Radiation Area Control Problems . . . . . . . . . . . . . . . . . . . 14
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Status of RP&C Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . 14
R2.1 Calibration of Effluent / Process Radiation Monitoring Systems
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R2.2 Air Cleaning Systems and Plant Air Balance . . . . . . . . . . . . . . . 16
R2.3 Radiologically Controlled Area Access Control and Electronic
Dosim eters (8 3 7 5 0) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
R3
RP&C Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . 18
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Staff Training and Qualification in RP&C . . . . . . . . . . . . . . . . . . . . . . 19
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RP&C Organization and Administration
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Quality Assurance (QA) in RP&C Activities . .
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R7.1
Effluents and Chemistry Ouality Assurance
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Table of Contents (cont'd)
R7.2 Radiation Protection Department Problem Reporting . . . . . . . . . 21
V. M a nageme nt Mee ting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
X1
Exit Meeting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
X2
Review of UFSAR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
ATTACHMENTS
Attachment 1:
Partial List of Persons Contacted
Inspection Procedures Used
items Opened, Closed, and Discussed
List of Acronyms Used
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Report Details
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Summarv of Plant Status
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_ Unit 1 started the inspection period at full power and remained at full power until May 17,
when power was briefly reduced for condenser water box cleaning and main turbine valve
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testing. On May 29, the unit was shut down to repair a primary leak (See Section 01.3).
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Unit 1 remained shutdown at the end of the inspection period.
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Unit 2 began the inspection period shutdown in a refueling outage. Power operation
resumed on May 23 and full power was achieved on May 31,1997.
1. Operation 1
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Conduct of Operations '
01.1 General Comments (71707)
Overall, the plant was operated safely. During a plant walkthrough on April 15, the
inspectors identified that a lock on the suction isolation valve for 11 auxiliary
feedwater pump was configured so that the lock and chain could be easily removed
without need of the key. The inspector informed control room personnel of the
discrepancy. Plant operators promptly responded, confirmed the inspector's
observation, and restored the lock to a secured position. BGE documented the
problem on an issue report and plant security was informed. There was no
indication of tampering and the valve was in its designated position. BGE
completed formal walkdowns of locked components throughout the plant and
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verified that alllocked valves were in the correct position. BGE considered the
auxiliary feedwater valve discrepancy was due to an open link type chain and
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initiated action to employ closed link chain for valve locking. The inspectors
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considered the problem to be an isolated occurrence and the BGE response
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appropriate to the circumstances.
The inspector observed portions of the Unit 2 startup from the refueling outage in
addition to the normal operating crew complement, a dedicated reactor operator and
senior reactor operator were assigned to focus on the control of the primary plant
during startup and low power physics testing. The inspectors observed that the
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dilution to initial criticality was well coordinated and safely conducted by operations
personnel through the use of a detailed pre-evolution brief, three-point
communications, self-checking techniques, and peer verifications of control
manipulations. After a portion of the low' power testing was completed, the reactor
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was taken sub-critical to perform a normal startup. During this startup and prior to
reaching the upper bounds of the estimated critical position limit, operations and
nuclear fuels personnel identified that the estimated critical rod position was
miscalculated due to uncertainties in the critical boron concentration measured
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' Topical headings such as 01, M1, etc., are used in accordance with the NRC standardized
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reactor inspection report outline found in MC 0610. Individual reports are not expected to
address all outline topics.
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during initial criticality. A more precise crstical boron concentration, although
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available, was not used in the estimated critical position. The reactor remained
subcritical while an evaluation of the occurrence was completed. The estimated -
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critical rod position' was recalculated using the more accurate measure of critical
boron ' concentration, and the reactor was taken critical within the limits of the
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re-estimated critical position. Operations l management performed supervisory
observations and provided management oversight for these evolutions. The
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inspector concluded that the startup from the Unit 2 refueling outage was
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conducted well.
01 2 12 HPSI Pumo Handswitch Mispositionino
a.
Scope
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The inspectors reviewed the circumstances surrounding the mispositioning of the
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12 high pressure safety injection (HPSI) pump handswitch.
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Findinas and Observations
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On May 8, a BGE senior licensed operator identified that the standby 12 HPSI pump
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was in the " auto" position versus its required " pull-to-lock" (PTL) position.' This
condition rendered the redundant 13 HPSl pump inoperable because the 13 pump
would not have automatically started on a safety injection actuation signal (SIAS).
Once discovered, the 12 HPSI pump handswitch was immediately restored to the
correct position. BGE also took corrective action to: perform breaker and valve
position verification surveillances; add additional switches, such as those that do
not alarm when taken out of their normal position to the turnover checklist; install
notes on the main control board concerning the required position on the 12 and
22 HPSI handswitches; and initiate a root cause analysis to fully evaluate.this
event.
Investigations by BGE personnel identified ;that the 12 HPSI handswitch had been
misaligned for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />, since the conclusion of troubleshooting that
placed the handswitch in the auto position. - At the time, the 13 HPSI pump was not
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declared inoperable, and Technical Specificttion Action Statement 3.5.2 had not
been entered. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time for the Technical Specification
action statement was not exceeded.
The inspectors noted that this misalignment was not identified for approximately
14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />, including a shift turnover control board.walkdown. The misalignment
- was identified by an oncoming senior reactor operator during the control board
walkdown for the subsequent day shift (i.e., the second shift turnover after the
mispositioning occurred).
~ The inspectors were concerned that this event was the third control switch
mispositioning event within the past year that was missed during the shift
turnover control board walkdowns. The first mispositioning occurred in August
1996, when the 11 header emergency core cooling system (ECCS) room cooler fan
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control handswitch was mispositioned after the 11 saltwater header was retumed
to service. This condition went undetected for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. See
NRC Inspection Report 50 317&318/96-06. The second event occurred on
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November 5,1996, when a loss of power to the flow instrumentation for service
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water to the containment air coolers was identified during a control board walkdown
by an operations support person. This condition was undetected by control room
operators for approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.
c.
Conclusions
BGE identified that the 12 HPSI pump handswitch had been misaligned following
troubleshooting. The troubleshooting control form restoration directed the
handswitch be placed in the incorrect " auto" position. The inspectors were
concemed that this event was the third control switch mispositioning in the last
year that was not identified during the control board walkdowns conducted for
licensed operator shift tumover. The inspectors considered the missed opportunity
to identify the misposition handswitch a weakness in the tumover process.
01.3 Reactor Coolant Leak on Unit 1
a.
insoection Scoce
The inspectors assessed BGE response to a smallloss of reactor coolant event on
Unit 1.
b.
Findinas and Observations
On May 29, at 4:27 p.m. a thermal margin low pressure pretrip occurred and
reactor operators observed that one of four channels of pressurizer pressure had
failed low. Subsequently, pressurizer and volume control tank levels dropped
slightly, and containment humidity and radiation levels went up. Plant operators
quickly and correctly diagnosed the event as a loss of coolant event and entered
Abnormal Operating Procedure 2A, " Excessive Reactor Coolant Leskage," which
directed actions to isolate the leak.
BGE declared an Unusual Event at 4:50 p.m. due to reactor coolant leakage that
required unit shutdown. The estimated leak rate was approximately 10 gallons per
minute. The operators determined, using control room indications, that the leak
was on a 3/4 inch stainless steelinstrument line that supplied the pressurizer
pressure instrument. As the reactor was shutdown, a containment entry was made
and the leak was isolated. The Unusual Event was then term'nated at 8:05 p.m.
The NRC inspectors responded to the control room and observed the reactor
shutdown and BGE activities to control and mitigate the event. Procedures were
appropriately used and an ample contingent of operators and support personnel
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were available to effectively complete the shutdown and leak isolation. There were
no complications to the event.
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BGE determined the leak was due to a failed compression fitting on the pressurizer
pressure instrument sensing line. While a root cause determination was being
conducted, BGE inspected other compression fittings used on both units. At the
end of the inspection period, no leaking compression fittings were found, although a
number of fittings were tightened,
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c.
Conclusions
The inspectors observed the BGE response to the Unit 1 reactor coolant leak and
found the activities effective in diagnosing and mitigating the event. The plant
shutdown was well controlled and the leak was quickly isolated. Support activities
including engineering, radiation protection, and maintenance were excellent and
ensured that there were no complications during the event.
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Operational Status of Facilities and Equipment
02.1 Enaineered Safetv Feature System Walkdown (71707)
The inspectors walked down accessible portions of the spent fuel pool cooling
system and determined that the system was properly aligned in accordance with the
operating procedures. Material condition 2nd housekeeping were good. Licensee
identified minor discrepancies were properly tagged. Several minor discrepancies
that were identified to the system engineer were promptly entered into the issue i
reporting system. The inspectors identified no substantive problems during the
system walkdown.
II. Maintenance
M1
Conduct of Maintenance
M 1.1 Routine Maintenance Observations (62707)
The inspector observed the conduct of maintenance and surveillance testing on
systems and components important to safety. The inspectors also reviewed
selected maintenance activities to assure that the work was performed safely and in
accordance with procedures. The inspectors noted that an appropriate level of
supervisory attention was given to the work depending on its priority and difficulty.
Maintenance activities reviewed included:
MO2199702954
Adjustment of Gain of Linear Range Nuclear instruments
MO2199604120
Replace 22A Reactor Coolant Pump Rotating Assembly
MO2199604119
Replace 21 A Reactor Coolant Pump Rotating Assembly
MOO 199701138
Replace OC Diesel Engine-Driven Fuel Oil Pump
M1.2 Routine Surveillance Observations (61726)
The inspector witnessed and reviewed selected surveillance tests to determine
whether approved procedures were in use, details were adequate, test
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instrumentation was calibrated and used, technical specifications were satisfied,
testing was performed by qualified personnel, and test results met acceptance
criteria or were appropriately dispositioned.
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The surveillance testing was performed safely and in accordance with proper
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procedures. The inspectors noted that an appropriate level of supervisory attention
was given to the testing depending on its sensitivity and difficulty. Surveillance
testing activities that were observed and reviewed included:
STP-047A
MSIV Partial Stroke Test
STP-M-212A
Channel A Reactor Protection System Functional Test
STP-M-571 C-2
Local Leak Rate Test, Penetrations 2A
(Letdown to Purif Demin),2B (RC Charging)
STP-M-471-2
Air Lock Operability and Local Leak Rate Test
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STP-M-213-2 '
Calibration of Power Range Nuclear instruments by
Comparison with incore Nuclear Instruments
STP-O-5A-2
Auxiliary Feedwater System Quarterly Surveillance Test
M1.3 Worker Iniured Durina Maintenance
On May 7, a contracted worker was injured when an electric motor and gearbox
assembly weighing approximately 75 pounds, fell from its support and struck the
worker in the hard hat and shoulder. At the time, the individual was completing
repairs to an overhead rollup door serviced by the motor and gearbox. The
individual remained conscious following the accident and was transported to Calvert
Memorial Hospital by ambulance. Although the work was done in a radiologically
controlled area, no contamination was found on the worker in preparation for offsite
transport. BGE initiated an investigation of the occurrence.
M1.4 Procurement Proaram
a.
Inspection Scope (38701)
The inspector reviewed aspects of BGE's procurement program for the iscuence,
return and inspection of spare parts, and equipment staged for field implementation.
The inspection was in part the result of an apparent increasing trend in the delivery
to the field of incorrect or defective parts. Procurement management and
engineering personnel were interviewed to assess their knowledge of the issues, as
well as implemented or anticipated corrective actions.
b.
_ Observations and Findinas
in early 1996, BGE implemented a warehouse management system (WMS) to better
track the receipt storage, and disbursement of spare parts and material for plant
modifications. At that time, the inspectors were given a tour of the warehouse
facility and a demonstration of WMS performance. Based on a review of issue
reports generated in the latter part of 1996, the inspectors noted that there were
fewer reports describing the delivery of defective or incorrect parts than had
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historically been the case,-indicating that the WMS had been effective in improving
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parts and material control performance. However, in the first quarter of 1997, and
particularly after the Unit 2 refueling outage began in mid-March, the inspectors
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noticed a pronounced increase in the number of issue reports detailing the delivery
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to the job site of incorrect or defective parts. in addition, several issue reports
indicated that in some instances, parts and material returned to the warehouse did
not conform to the original procurement documentation.
The inspector discussed the incorrect parts issue with procurement management,
who stated that there had been a site-wide program in 1996 to return both safety
and non safety-related parts and equipment to the warehouse. Returned items were
receipt inspected prior to being placed in stock. However, the inspectors noted that
the inspection was not always of sufficient rigM to identify deficiencies which might
not be immediately visible. In some cases, re'.urned items were then the first items
issued when needed in the field. The inspectors considered this practice to have
been weak with the potential to introduce degraded or defective components in
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safety-related applications and whose condition might not be apparent during post-
maintenance or implementation testing. While root cause analyses for several of
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the recent issue reports dealing with defective parts delivered to the jobsite were
pending, BGE stated that preliminary indications were that these parts had been
returned to the warehouse in 1996, but had not been noted as being degraded or
defective.
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The inspector found several other apparent causes for delivery of incorrect parts,
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Recently, BGE implemented a corporate-wide business information system (BIS)
which was to integrate allinformation-based data systems used at various BGE
locations. However, BIS did not interface effectively with the WMS in use at
Calvert Cliffs. In the meantime, several data bases used to control inventories had
been eliminated, causing a degradation in parts and material control. The inspectors
considered the length of time expended on resolving the BIS /WMS interface
compatibility problems to be excessive and was reflective of poor change
management by BGE.
The inspector reviewed a recently completed BGE audit (97-01) covering
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procurement and materials management. The audit was of sufficient scope to
support the conclusion that the procurement program was generally effective in
procuring and controlling items and services. The audit did not reveal any safety-
significant weaknesses, although the effectiveness and timeliness of corrective
actions for some shelf-life and storage issues were noted to be unsatisfactory. The
inspectors discussed the results of the audit with procurement management, who
indicated that not all of the thirteen recommendations had been accepted,
specifically recommendations dealing with increased inspections and checks of
equipment where problems had not been identified to date. The inspectors
concluded that the rationale behind the rejection of several such recommendations
appeared reasonable.
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fifteen months to strengthen the procurement process, including:
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implementation'of the warehouse management system
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Procedure enhancements to streamline and simplify procurement and
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procurement engineering procet.ses
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Procurement process training for interfacing engineers and planners
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Enhancements to the commercial grade dedication program
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The inspector considered these initiatives to reflect BGE's efforts to improve the
procurement process and address several long-standing deficiencies. An audit by
independent engineering personnel conducted in June 1997, indicated that some
improvements have resulted from these efforts with regard to safety-related parts
and equipment. However, the inspectors noted that neither the June 1997 audit
nor internal BGE procurement assessments addressed how effectively BGE managed
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issues with non safety-related parts whose failure could affect safety-related
equipment. This was a weakness in BGE's procurement program which requires
additional management attention.
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c.
Conclusions
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The implementation of the warehouse management system contributed to the
reduction in the delivery of incorrect or defective parts to work sites. However, the
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return of many spare parts from the field in 1996 may not have included adequate
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receipt inspection prior to being replaced in stock. This problem may have
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contributed to an increasing trend of improper deliveries noted in 1997. The
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practice of re-issuing these parts was weak and had the potential to introduce
degraded or defective parts in safety-related applications where testing might not
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reveal problems. The BIS /WMS interface difficulty was a problem with change
management.
M8
Miscelleneous Maintenance issues
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M8.1 (Closed) LER 50-317/96-04-00 Two ASI Channels OOS Due to Reversed Nuclear
Instrumentation Leads
The Licensee Event Report (LER) described the discovery that the axial shape index
for Unit 1 Reactor Protective System Channels B and C were out of service due to
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the reversal of the associated upper and lower linear range nuclear instrument
detector leads. The causes of this event were personnel error in not recognizing
j
changes to or the importance of detector labeling, and inadequate procedure
guidance to ensure proper cable connection. An opportunity to find the problem
,
was missed during the post-installation test. The leads were correctly reconnected
on August 2,1996. The inspectors verified the corrective actions stated in the LER
including: performance of root cause analyses, enhancement of the installation and
test procedure, and strengthening of related procurement documentation and receipt
inspection procedures. The LER was closed as a Non-Cited Violation in accordance
with Section Vll.B.1 of NUREG 1600, NRC Enforcement Policy. A related item
.
_
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_
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_ ,
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.
8
(URI 50-317&318/96-06-02) that was unresolved pending completion of the BGE
root cause analyses was also closed.
M8.2 (Closed) LER 050-317/96-03: Discoverv of Holes in the Containment Sumo Screen
to Facilitate Field Run Tubina
The Licensee Event Report described the discovery of two approximately three inch
by six inch holes in the containment sump screens for Units 1 and 2. BGE stated
that the holes were likely field installed during initial plant construction and were
made to allow instrument tubing to pass into the sumps. Upon discovery, BGE
closed the holes by welding stainless steel plates over the openings. The inspectors
observed that the penetrations had been closed. After observing the holes and their
orientation, the inspectors concluded that the threat to the sump from material
passing through the holes was negligible. The BGE actions to identify and correct
,
the penetrations was appropriate. The LER is closed.
'
ill. Enaineerina
E2
Engineering Support of Facilities and Equipment
E2.1
(Uodate) URI 50-317&318/96-06-03: Salt Water and Service Water Systems
1
Continued Ooerability
a.
Insoection Scone (37550)
The inspectors reviewed the BGE efforts to ensure service water system reliability
during summer Chesapeake Bay water temperatures.
1
b.
Findinos and Observations
In January 1996, while reviewing data collected to quantify the tube side (or micro-)
fouling factor, BGE determined that the equilibrium micro-fouling factor assumed in
the service water heat exchanger (SRWHX) thermal performance calculations was
too small. This issue was documented in NRC Inspection Report (IR)
50-317&318/96-01 and in Licensee Event Report (LER) 50-317/96-01.
'
Prior to this discovery, BGE design calculations had established the maximum
allowed Chesapeake Bay water temperature for service water subsystem operability
l
at 87.4 degrees Fahrenheit ( F). The fouling factor data indicated that to
continue to use the same rnicro-fouling factor and retain the same maximum
temperature limit, BGE would be required to clean the individual tubes in the
SRWHX every 14 days. BGE sought additional means to increase the design margin
of the SW and SRW systems and completed a 1996 bi-weekly cleaning schedule for
the SRWHX as bay temperatures rose above 70 F.
1
BGE sought to restore the lost design margin by replacing the fixed flow stops on
the containment air cooler (CAC) SRW inlet control valve actuators with flow
control devices. The intended finer control of SRW flow would remove uncertainty
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_ - _ _ _ _ _ _ __ ... _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . ..
1
i
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1
,
l
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9
from the design calculations and therefore increase margin lost to the increase in
[
the micro-fouling factor. Since this modification involved an unreviewed safety
l
question, a license amendment was obtained from the NRC, and the modification
j
was installed in both units in 1996.
During surveillance testing in December 1996, the containment air cooler-service
,
water inlet control valves demonstrated unstable behavior. A temporary
l
modification was installed to disable the flow controllers and reinstall the
4
mechanical stops in the control valves until the instability of the flow controllers
could be resolved. The return to the mechanical stops was expected to reduce the
i
maximum allowable Chesapeake Bay water temperature by 2*F.
i.
BGE continued to collect additional fouling factor data using a single tube model of
the SRWHX called a side stream monitor. BGE reviewed this data and determined
,
l
that, although .the equilibrium micro-fouling factor remained the same, the time to
j
reach a' limiting micro-fouling factor was reduced from approximately 14 to
j
approximately 9 days,
j
'
'BGE determined that cleaning the SRWHXs on a frequency of every 9 days would
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_
not be prudent. The related thermal performance calculations were being
j
recalculated using the equilibrium micro-fouling factor. Using the equilibrium micro-
fouling factor would provide an extended period of time between cleanings for
,
micro-fouling. Bay water inlet temperature, SRWHX differential pressure, and flow
]
,
through the SRWHX would continue to be monitored to determine when cleaning
-
was required for macro-fouling.
BGE considered several additional measures to increase the maximum allowable
inlet water temperature. Among the measures, BGE planned to quantify the
capacity of each of the normal service water pumps. Using the information
i
obtained from these tests in the thermal performance calculations was expected to
{
reduce the uncertainty in the calculations and increase the design margin. BGE's
preliminary estimate of the increase in margin is l'F.
BGE also considered throttling the SRW flow to the EDGs and making it a safety-
related function by the installation of a safety-related backup supply (nitrogen
accumulator) to the air operator for the EDG SRW control valve operator. Once
completed the maximum saltwater inlet temperature limits will be 88*F for 11 train
and 86*F for the 12,21, and 22 trains of cooling water. This modification is
j
scheduled for completion in July 1997.
'
Another option was to take one of the four containment air coolers out-of-service
and enter the related technical specification action statement when the salt water
maximum temperature limits were approached. Taking a containment air cooler out--
of-service was to reduce the amount of post-accident heat rejected to the SRW
I
header, and therefore, reduce the peak SRW header temperature below the EDG-
design limit of 105'F. BGE estimated that implementing this option could raise the
maximum inlet saltwater temperature for each train to as high as 90*F. BGE
continued to review the potential safety and regulatory impacts of this option.
'
.
10
BGE also stated that the final actions for increasing bay water temperature would be
included in a procedure upgrado and would receive review by the plant operational
safety review committee. The action plan would receive a 10 CFR 50.59 screen to
ensure that an unreviewed safety question was not involved.
l
c.
Conclusions
Changing conditions, such as the fouling factors and fouling rates on operability of
the service water system has continued to challenge BGE. The inspectors
concluded that BGE has continued to be proactive in testing and engineering work
related to the service water system reliability. Until the scheduled replacement of
the SRWHXs in 1998 (Unit 1) and 1999 (Unit 2), this proactive approach appears
commensurate with the safety significance of the system. However, NRC review of
the BGE action plan and operating procedures for high Chesapeake bay
temperatures will be necessary to close the unresolved item.
E8
Miscellaneous Engineering issues
.
E8.1
(Closed) Unresolved Item 50-317&318/94-24-02: Reactor Coolant Code Safety
Valve Performance issues
a.
Inspection Scone (92903)
The inspector reviewed the unresolved item which involved BGE's investigation into
the causes behind the seat leakage from the reactor coolant system (RCS) safety
valves (SRVs) 1-RV-200 and 1-RV-201, as well as potential discrepancies in the
procedures and facilities used to set / adjust the safety valve lift setpoint.
b.
Observations and Findinas
BGE determined that the seat leakage from the two safety relief valves in 1994 was
caused by unrelated circumstances. In the first case,1-RV-201 had been shipped
to a vendor for disassembly and inspection. The vendor found that the valve had
lifted prematurely in 1994 because the disc holder had been improperly staked,
allowing it to contact the lower adjusting ring. Steam leaking past the seat then
effectively worked against the seating force of the SRV spring, resulting in a lower
lifting point. Misalignment of the disc holder also caused internal damage to the
SRV such that it did not fully reseat following the original lift, resulting in the high
leak rate observed after the transient. The vendor concluded that the internal
damage would not have prevented the SRV from lifting again should pressure have
increased beyond the lift setpoint. BGE also performed an extensive root cause
analysis (RCA) and developed a number of corrective actions, including an
inspection of 1-RV-201 during the 1996 refueling outage which validated the
assumptions and corrective actions of the root cause analysis.
BGE also evaluated whether the deferral of the replacement of 1-RV-201 during the
1994 refueling outage contributed to the valve's leakage. BGE system engineering
concluded that the reasons for the deferral were sound, given the excellent
_._
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.
11
!
performance of 1-RV-201 up to that point. Several SRVs had been in service for
fifteen years without notable problems prior to BGE's implementation of a routine
l
preventive maintenance program in 1991.
'
in the case of relief valve,1-RV-200 seat leakage, BGE engineering personnel noted
i
that several different SRVs in this position had leaked previously in .1984,1986 and
1992. Following extensive walkdowns and evaluations,' BGE engineers determined
that several SRV discharge piping supports (sway struts and spring hangers) were
either misaligned or improperly loaded, which, as the pressurizer expanded during
plant heatup, imparted a bending force to the SRV discharge nozzle, which distorted
the valve seat, allowing leakage to occur. BGE could not determine exactly when
the supports became misaligned, but suspected it may have occurred when the
pressurizer spray valves were relocated to the top of the pressurizer " dog house" in
the early 1980s. The piping supports were returned to their original configuration in
1
1994. Relief valve,1-RV-200 was inspected during the 1996 refueling outage and
,
there was no indication of seat leakage or piping stresses beyond design limits.
. BGE evaluated the causes behind the consistent setpoint difference between the as-
f
left at the laboratory and what was found after the valve was re-installed in the
'
plant. BGE determined that almost all of the difference was attributable to the use
of differing ternperature profiles BGE's profile used data gathered over the previous-
!
three years, while the laboratory profile used original construction data which had
not been updated. Some minor enhancements to the Hydroset test procedure
accounted for the remaining difference. The laboratory profiles were updated and
BGE engineers validated these conclusions during the Unit 2 refueling outage in-
1995.
c.
Conclusions
BGE's root cause analyses for the problems with 1-RV-200 and -201 in 1994 were
comprehensive and very thorough. Given that in both cases there were significant
raw data lapses due to unrelated equipment performance issues, the inspectors-
noted that BGE engineering personnel paid special attention to the validation of their
assumptions and the effectiveness of their corrective actions. The inspectors
concluded that BGE's actions were effective, as demonstrated by satisfactory SRV
performance since July 1994, including no recurrence of seat leakage. This item is
therefore closed.
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IV. Plant Support
4
R1
Radiological Protection and Chemistry (RP&C) Controls
R1.1 Imolementation of the Radioactive Liould and Gaseous Effluent Control Proarams
)
a.
Insoection Scope (84750)
The inspection consisted of: a tour of radioactive liquid and gaseous effluent
pathways and the BGE process facilities, and control room; a review of radioactive
liquid and gaseous effluent release permits; a review of unplanned or unmonitored
i
release pathways; and review of the quantification technique for the airborne tritium
i
release.
b.
Ohservations and Findinos
The inspector toured the control room radiation monitoring station and selected
radioactive liquid and gas processing facilities and equipr.1ent, including effluent
radiation monitors and air cleaning systems. All equipment was operable at the
time of the tour. Effluent / process / area radiation monitors were also operable with
the exception of Unit 2 main steam line monitors which were being calibrated.
During review of selected radioactive liquid and gaseous effluent discharge permits,
the inspector determined that 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.
The inspector also noted that there were no unplanned /unmonitored radioactive
liquid and gas releases since the previous inspection conducted in February 1996.
The inspectors noted that BGE had reviewed the effluent control programs relative
to IE Bulletin No. 80-10, " Contamination of Nonradioactive System and Resulting
Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment."
The inspector requested BGE demonstrate the capability for monitoring and
quantifying airborne tritium. BGE calculated the total amount of water loss from
the spent fuel pool (SFP). BGE assumed that water loss was due to evaporation
from the SFP released to the environment via the plant vent. BGE calculated the
airborne tritium released using SFP tritium measurement results. Calculated
airborne tritium released through the plant vent during the second half of 1996
was 1.16 curies. BGE reported, in the second half of 1996, " Semiannual Effluent
Report," that 1.49 curies of airborne tritium was released. The inspector
determined that BGE's assumptions and calculation methodologies were effective in
monitoring and quantifying airborne tritium releases.
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13
c.
Conclusions
Based on the above reviews, the inspector determined that BGE maintained and
implemented very good radioactive liquid and gaseous effluent control programs.
i
R1.2 Imolementation of the Effluent ALARA Proaram
a.
Insoection Scone (84750-01)
The chemistry department implemented the Chemistry Business Plan in February
1996 and the effluent ALARA program was a major part of this plan. During this
inspection, the inspector reviewed: (1) comparisons between projected radioactive
liquid and gaseous releases and actual releases during 1996; (2) participation of
other supporting groups (e.g., HP, l&C, system engineers, and operations) to the
program; (3) communicstion; and (4) safety focus.
j
b.
Observations and Findinas
i
The projected tota! smount of radioactive liquid and gaseous effluents released
during 1996 were 214 millicuries and 80 curies, respectively. The 1996 actual
'
releases of liquid and gaseous effluents were 220 millicuries and 77.4 curies,
respectively, indicating that BGE was effective in monitoring and controlling effluent
releases.
Participation of other supporting groups (i.e., staff from operations, maintenance,
engineering, and radiation control departments) to support the effluent ALARA
program was good. For example, chemistry and engineering / technical staff made .
efforts to optimize system performance to reduce the radioactive liquid and gaseous
effluent releases to the environment. The inspector also noted that management
supported the effluent ALARA program and efforts to minimize radiological releases
to the environment.
Good communications between the chemistry staff and other supporting groups
(operations, maintenance, engineering, and radiation control) were noted. The
chemistry organization also provided technical training to other organizations. For
example, training topics for the control room operators were: (1) secondary
chemistry, including S/G corrosion; (2) implementation of the ODCM; (3) outage
chemistry, including reactor coolant system degasification, and liquid and gaseous
waste controls; and (4) primary chemistry principles. A similar training program
was developed by the chemistry staff for engineering / technical initial training and
system engineering training,
c.
Conclusions
Based on the above reviews, the inspector determined that BGE maintained and
implemented a very good effluent ALARA program.
.
.
14
R1.3 Hiah Radiation Area Control Problems
On May 1,1997, BGE identified that an electrician had entered the Unit 2
containment and had worked for over one hour m a locked high radiation area
without the required dosimetry. The individual had entered the radiologically
controlled area with the proper dosimetry for the job, but had removed the
dosimetry during dressout for the containment entry. Subsequently, the individual
entered the containment with no dosimetry. About an hour later, another BGE
employee saw the dosimetry and reported the finding to radiation controls
personnel. The electrician was informed and immediately directed out of the
radiation area.
On May 4,1997, BGE identified that during the construction of scaffolding in
the radiologically controlled area, a high radiation area was inadvertently
entered. As individuals constructed the third tier of the scaffolding, the worker's
electronic personnel dosimeters alarmed. The individuals irnmediately informed
radiation controls personnel, a survey was performed, and a maximum dose rate of
300 mrem per hour was found. The area had not been previously surveyed. Work
was stopped until an evaluation was completed.
BGE discussed these events with NRC personnel on May 1 and May 5,1997.
Subsequently, BGE documented the occurrences and corrective actions taken in a
letter to NRC Region I, dated May 9,1997. These events were also discussed at a
predecisional enforcement conference held on June 12,1997. Since the two
events involved non-compliance with BGE procedures for control of high radiation
area access, and were additional examples of recent high radiation area control
problems, they were considered apparent violations of NRC requirements.
Enforcement action for the two events will be addressed in a separate
correspondence.
R2
Status of RP&C Facilities and Equipment
R2.1 Calibration of Effluent / Process Radiation Monitorina Systems
a.
insoection Scone (84750)
The inspector reviewed: (1) the most recent calibration results for the following
selected effluent / process / area radiation monitoring systems and their system flow
rates; (2) an RMS self-assessment; and (3) the quarterly trending reports.
Liquid Radwaste Effluent Monitor (Common)
Liquid Radwaste Effluent Line Flow Rate Measuring Device
Steam Generator Blowdown Radiation Monitors (Units 1 and 2)
Steam Generator Blowdown Line Flow Rate Measuring Device
Main Steam Line Monitors (Units 1 and 2)
Main / Plant Vents Noble Gas Monitors (Units 1 and 2)
Wide Range Noble Gas Monitors (Units 1 and 2)
Waste Gas Discharge Noble Gas Monitor (Common)
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_ . . - .
I
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4 '*
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15
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]
e
Waste Gas Effluent System Flow Rate Measuring Device
o
. Containment Purge Radiation Monitors (Units 1 and 2)
Condenser Air Evacuators Discharge Monitors (Units 1 and 2)
..
{
e
Containment Area High Range Monitors (Units 1 and 2)
!
Spent Fuel Pool Platform Area Monitor (Common)
e
Access Control Area Vent Monitor (Common)
e
Control Room Vent Gaseous Monitor (Common)
i
l
b.
Observations and Findinas
!
.
[
The instrumentation and controls department had the responsibility to perform
i
electronic and radiological calibrations for the above radiation monitors. The
i
!
system engineer had the responsibility to trend and track the above RMS. All
.
reviewed calibration results were within BGE's acceptance criteria, with the
!
!
exception of Unit 2 main steam line monitors which were_ newly installed and were
j
.being calibrated. Calibration results will be reviewed during a subsequent
'
inspection.
l
' During the review of the above RMS calibration documentation, the inspector
)
.
independently calculated and compared several calibration results, including linearity
j
-
"
tests and conversion factors. The inspector determined that BGE's results were
comparable to the independent calculations.
)
BGE applied very good calibration methodologies for the above area radiation
i
monitoring systems, including radiological and electronic calibrations. Alarm -
setpoint calculation methodologies were good. Calibration procedures were detailed
and easy to follow.
The inspector also reviewed RMS assessment and quarterly trending reports that
were prepared by the RMS system manager. The RMS system manager assessed
the system availability using a tracking system (e.g.,99.5% availability of the
Unit.2 wide range gas monitor during 1996). The inspectors determined that the
RMS . system manager and engineer provided focus and attention in the areas of:
)
(1) RMS upgrade project; (2) RMS system improvement project; (3) trending
analyses for conversion factors and linearities; and (4) follow-up'on the progress of
modifications.
i
c.
Conclusions
Based on the above reviews, the inspector determined that BGE maintained and
implemented good calibration and assessment / trending programs for
effluent / process / area radiation monitoring systems.
)
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-.
. .
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.,
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,
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.
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16
R2.2 Air Cleanina Systems and Plant Air Balance
a.
Insoection Scope (84750)
The inspector reviewed BGE's most recent surveillance test results (visual
inspection, in-place HEPA and charcoal filter leak tests, air capacity / pressure drop
tests, and laboratory tests for the iodine collection efficiencies) for the following
systems:
Control Room Emergency Air Supply Systems,
Spent Fuel Handling Building,
Penetration Room Exhaust System,
Containment Building, and
ECCS Pump Room Exhaust System.
The inspectors reviewed the plant air balance for the following facilities as described
in Section 9.8.2.3 of the UFSAR:
Positive pressure for the Control Room,
Negative pressure for the Waste Processing Area, and
Negative pressure for the Spent Fuel Pool Ventilation.
b.
Observations and Findinas
All reviewed surneillance test results were within Calvert Cliffs technical
specification acceptance criteria. During discussions with the responsible individual,
the inspector noted that the individual had very good knowledge not only for
technical specification requirements, but also for standard industry practices. As
noted in inspection report no. 50-317/96-02 and 50-318/96-02, BGE previously
identified a weakness concerning the test temperature (130*C) for the iodine
collection efficiency test as specified by the TS As a result, BGE tests the charcoal
filter system at both 130 C and 30 C. The inspector determined that BGE
maintained and implemented a good routine surveillance test program.
Maintaining positive and negative pressures for the above systems appeared to be
acceptable, however, there were no pressure differences in the measurement
devices for the above f acilities. BGE verified appropriate positive / negative pressures
by periodic smoke testing. The inspector noted that periodic smoke testing to verify
positive / negative pressures for the above facilities was difficult because there were
different ventilation system configurations. BGE was considering the installation of
differential pressure gauges for the above systems.
)
!
BGE submitted a Licensee Event Report (50-318/97-001) to the NRC regarding the
air balance between the Spent Fuel Pool (SFP) area and the auxiliary building while
fuel was being moved in the SFP. There were no differential pressure measurement
!
devices for the SFP and auxiliary building, and BGE did not identify air flow
direction. Pressure of the auxiliary building was more strongly negative than that of
the SFP, therefore, the air from the SFP leaked into the auxiliary building. The
)
.
'
,
17
inspector noted that air in the SFP was required to pass through the SFP ventilation
system (charcoal and HEPA filters) in the event of a fuel handling accident.
BGE stated in the LER that procedures were being revised to ensure that the SFP
ventilation remained operable when auxiliary building ventilation lineup changes
were made,
c.
Conclusions
Based on the above reviews, the inspector determined that BGE maintained and
implemented a good routine surveillance test program. The responsible individual
for ventilation had very good knowledge not only for technical specification
requirements, but also for standard industry practices. BGE implemented action to
ensure that ventilation system configuration changes did not affect ventilation
design.
R2.3 Radioloaically Controlled Area Access Control and Electronic Dosimeters (83750)
a.
Inspection Scope
The BGE Radiologically Controlled Area (RCA) access control and electronic
personal dosimeter (EPD) system was evaluated through discussions with radiation
protection staff and the following documents:
Enhanced Radiation Worker Training, General Orientation Training (GOT)
Lesson Plan GOT-337-9, Revision 1, January 15,1997
GOT Annual Requalification, Lesson Plan GOT-337-27R, Revision 5
GOT Initial Training, Lesson Plan GOT-337-27, Revision 11
IR1 -019-441, Issue Report, Improper RCA Entry, April 29,1997
First Quarter 1997 Exposure Evaluation Reports
First Quarter Thermoluminescent Dosimeters (TLDs)/EPD Error Evaluation
Reports
Second Quarter 1997 Exposure Evaluation Reports
First Quarter 1997 EPD Loss / Failure Reports
Second Quarter 1997 EPD Loss / Failure Reports
b.
Observations and Findinas
The inspector found that GOT training emphasized how to properly use the
EPD/ access control system. The GOT initial test evaluated worker knowledge on
EPD access control. GOT requalification tests asked several questions regarding
RCA access control.
BGE informed the inspector that TLDs were the device of record used to measure
dose. BGE stated that EPDs were used as a control device only. NRC regulation
10 CFR 20.1501(c)(1) required that processed dosimeters used to comply with
10 CFR 20.1201 were required to be National Voluntary Laboratory Accreditation
Program (NVLAP) accredited. The BGE TLD program was accredited by NVLAP.
.
.
18
The inspector noted that TLD results demonstrated that worker exposures have
been well within the federal regulatory limit of five rem in a year.
The inspector found that BGE programmed the EPD/ access control system to
'
provide both visual (CRT monitor) and audio (computer soundboard) warnings if the
EPD was removed prior to completing the log-in access transaction. While it was
possible for an individual to remove an EPD prior to the completion of the access
transaction, visual and audible alarms sounded. An individual would have to ignore
these wamings that RCA access had not been granted.
l
Several cases were identified by BGE in which a worker received an error message
upon exiting the RCA. BGE investigation into these cases indicated that the worker
had failed to check the EPD for the HPID# (a self-check to insure that the electronic
transaction was succest.ful). The inspector reviewed one issue Report detailing an
.
'
event in which a worker entered the RCA without having properly completed the
Real Time Exposure Management System (REMS) log-in. The issue Report was
generated on April 29,1997, and the accompanying REMS transaction log indicated
that the EPD had been removed prior to completion of the sign-in.
The inspector reviewed several EPD failure reports. The inspector assessed that the
actions ar.d assumptions taken by BGE to evaluate worker doses in these cases of
lost or failed EPDs were reasonable (worker doses were evaluated and tracked as a
temporary control measure until TLD results were acquired). The inspector found
that individuals who failed to make proper RCA entries had received disciplinary
action.
c.
Conclusions
No issues other than some human performance problems were noted regarding the
electronic access control and electronic dosimeter system. BGE reviewed cases in
which EPDs were lost, failed, or provided anomalous readings. The actions taken
and the assumptions made in these cases were reasonable.
R3
RP&C Procedures and Documentation
a.
Inspection Scope (845'70)
The inspection consisted of: (1) review of selected chemistry procedures to
determine whether BGE could implement the routine radioactive liquid and gaseous
effluent control programs and the emergency operations; (2) review of 1995 and
1996 Semiannual Radioactive Effluent Reports to verify the implementation of TS
requirements; and (3) review of the contents of the ODCM for performing the
effluent control programs, including methodologies for calculating projected dose to
the public.
.
19
b.
Observations and Findinas
The inspector noted that effluent control procedures were detailed, easy to follow,
and ODCM requirements were incorporated into the appropriate procedures. BGE
had good procedures to satisfy the TS/ODCM requirements for routine and
emergency operations.
The inspector reviewed the 1995 and 1996 Semiannual Radioactive Effluent
Release Reports. These reports provided data indicating total radioactivity released
for liquid and gaseous effluents. The annual reports also summarized the
assessment of the projected maximum individual and population doses resulting
from routine radioactive airborne and liquid effluents. Projected doses to the public
were well below the Technical Specification (TS) limits. The inspector determined
that there were no anomalous measurements, omissions, or adverse trends in the
reports.
The ODCM provided descriptions of the sampling and analysis programs, which are
established for quantifying radioactive liquid and gaseous effluent concentrations,
ar;d for calculating projected doses to the public. Methods for establishing effluent
radiation monitor setpoints were listed in the ODCM. BGE adopted other necessary
parameters from Regulatory Guide 1.109.
c.
Conclusions
Based on the above reviews, the inspector made the following deterrninations:
e
effluent control procedures were sufficiently detailed to facilitate
performance of all necessary steps for routine and emergency operations,
e
BGE effectively implemented the TS/ODCM requirements for reporting
effluent releases and projected doses to the public, and
BGE's ODCM contained sufficient specification, information, and instruction
to acceptably implement and maintain the radioactive liquid and gaseous
effluent control programs.
R5
Staff Training and Qualification in RP&C
The inspection consisted of: (1) discussions with a chemistry training instructor,
(2) a review of the training manuals, and (3) a review of chemistry technicians
training records,
The inspector reviewed a selected portion of the chemistry training manual for the
chemistry technicians. The training manual contained good information about
chemistry laboratory techniques and appropriate learning objectives and training
sequences. The chemistry training instructor stated that the expectation was that
the trainees were to clearly understand the importance of each laboratory analytical
step and effectively perform the requirement. The annual training and as-needed
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20
a
training (on-the-job) were required as part of the training. The passing grade was
80%. The inspector also reviewed the training records for chemistry technicians
,
l
and verified that the training requirements were met.
'
!
Based on the above review and discussions, the inspector determined that the
training department implemented an effective training program for chem!Mry
"
technicians.
R8
RP&C Organization and Administration
,
The inspector reviewed the organization and administration of the radioactive liquid
and gaseous effluent control programs and discussed changes made since the last
inspection, conducted in February 1996.'
There were no program changes since the last inspection. The chemistry
department had the major responsibility to conduct the effluent control programs.-
Other groups (i.e., radiation controls, operations, l&C, and system engineers) had
supporting responsibilities to the program. Staffing levels appeared to be
appropriate for the conduct of routine and emergency operations.
R7.
Quality Assurance (QA)in RP&C Activities
R7.1
Effluents and Chemistry Quality Assurance
a.
Inspection Scope (84750)
The inspection consisted of: (1) review of the 1996 audit and its responses; (2) QA
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policy of the measurement laboratory; and (3) implementation of the measurement
laboratory QC program for radioactive liquid and gaseous effluent samples.
b.
Observations and Findinas
The inspector reviewed QA audit report No. 96-16, " Chemistry." The inspector
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noted that the audit team also included other technical personnel. The 1996 audit
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team identified one finding. The finding was not safety-related, but rather
recommended an enhancement to the effluent control programs. The response to
this finding was completed in a timely manner. The inspector noted that the scope
and technical depth of the audit was sufficient to assess the quality of the.
radioactive liquid and gaseous effluent control programs.
BGE maintained a good QA policy and implemented the policy throughout the
chemistry department, including analytical measurement laboratory. The inspector
reviewed the QC data for intra /interlaboratory comparisons. When discrepancies
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were found, effective resolutions were determined and implemented.
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c.
Conclusions
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Based on the above reviews, the inspector determined that BGE's OA audit was
sufficient to effectively assess the radioactive liquid and gaseous effluent control
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programs. BGE implemented a very good QA/QC program to validate measurement
results for effluent samples.
R7.2 Radiation Protection Department Problem Reportina
a.
Inspection Scooe
The inspector reviewed problem reporting activities in the Calvert Cliffs radiation
protection department,
b.
Findinas and Observations
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A number of BGE and contractor radiation protection technicians were asked how
problems were reported and the receptiveness of BGE management to problem
reports. All of the selected individuals stated that issues were documented on gold
cards, which were available at the radiation protection control desk. Issue reports
were typically only initiated by supervisors after reviewing the gold cards. Of the
individuals interviewed, some stated that supervision was generally receptive to
worker concerns and would take appropriate action to resolve concerns when
identified. However, some workers stated that concerns sometimes were not
promptly answered.
Ar, followup to the worker concerns, the inspector reviewed gold cards collected
during the Unit 2 outage to determine if identified deficiencies were being
dispositioned in accordance with BGE policy and procedures. Approximately
200 gold cards were reviewed. The inspector found that most issues were
appropriate for gold card documentation, such as good performance by technicians
in the field or suggestions for process improvements. All of the gold cards had
been reviewed by supervisory and management personnel in the radiation protec'. ion
department. Most of the gold cards had not been entered into radiation protection
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department computer based trending system. The filing and entering into the
tracking system was in progress at the time of the inspection. A number of gold
cards identified procedure or process deficiencies and these were upgraded to issue
reports by the reviewing supervisor. Issues in this group included:
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On April 5, a small spill of potentially contaminated water from a tank truck
occurred due to an improper valve lineup.
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On April 10, an air sampler was found out-of-calibration. The sampler had
been used four times prior to identification of the problem.
The inspector found one gold card that identified a personnel safety issues that had
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not been upgraded to an issue report. Although the issue was entered in the
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radiation controls tracking system, resolution of the concerns was not apparent.
The issue was as follows:
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On March 22, an individual observed personnel attaching safety tethers
improperly, doubling tethers, and working without tethers on the edge of the
refuel pool.
No investigation had been conducted into the observations even though the
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observations of working without tethers and doubling tethers were contrary to both
BGE and United States Occupational Safety and Health Administration Guidelines.
Maintenance and radiation protection department management informed the
inspector that they did not believe that work was conducted without tethers and
that the observer was likely in error; however, no investigation had been conducted
at the time of the observation and the concerns were unanswered until questions
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were raised by the inspector.
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The inspector found four additional gold cards that involved procedure compliance
issues. None of these issues were documented as issue reports and corrective
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actions were not documented:
On March 15, technicians respor.ded to a personnel contamination. The
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decontamination effort was not dane in accordance with BGE procedure
RSP-1-107.
On April 4, an unused ty-wrap wai, found floating in the refuel pool. (The
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refuel pool was a foreign materialt exclusion zone.)
On April 8, BGE identified that personnel were changing alarming dosimeter
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calibration setpoints in the field. One reason was that the radiation safety
procedure RSP-1-129 was not being followed.
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On April 13, three Cobalt-60 sources were returned to Calvert Cliffs by a
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vendor as a limited quantity shipment. The receipt survey showed up to
1 millirem per hour on contact, which is greater than limited quantity. The
package may not have considered Department of Transportation regulations.
The inspector reviewed these issues and found that some corrective actions had
been implemented for each of the concerns. For example, for the April 8 issue, field
personnel were re-trained on setting SAIC dosimeter setpoints. However, the
inspector considered the BGE practice of using gold cards to document procedure
compliance issues to be a poor practice because interdisciplinary review and station
wide trending were not done. Also none of the issues received review by
management outside of the radiation protection department.
The inspector discussed these concerns with BGE management. The radiation
protection department manager stated that the radiation protection staff would be
retrained on Calvert Cliffs problem reporting and this training was completed for all
radiation protection supervisors and managers. Also issue reports were written for
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all procedure compliance issues, including past issues identified during the outage
using the gold card system. Additionally, the radiation protection department
weekly staff meeting began to include a review of allissue reports and gold cards
written for the week, and gold cards were to be evaluated by management to
determine if an issue report was appropriate.
BGE procedure OL-2-100, " Issue Reporting and Assessment," stated that "All
personnel at CCNPP are responsible for identifying and promptly documenting
deficiencies and nonconformances on issue reports." Further, QL-2-100 specified
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an issue report for an actual or suspected process or program deficiency or
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nonconformance. The issue resolution sponsor for the issue report shall be
responsible for evaluating the issue, initiating corrective actions, and verifying
completion of all actions necessary to fully resolve the issue described on the issue
report. Upon completion of all required actions, the sponsor shall provide a
resolution document to describe actions taken to resolve the issue. The document
shall provide sufficient detail to ensure a reasonable understanding of the issue, its
cause, and its resolution. For the March 15, April 8 and 13 problems, issue reports
were not written and corrective actions were not documented as specified by
Calvert Cliffs procedure OL-2-100. These failures were considered a violation of
NRC requirements, (VIO 50 317&318/97-03-01)
c.
Conclusions
The inspector found that the radiation protection department did not generate issue
reports for some worker concerns and some concerns were not promptly resolved.
Among the unresolved concerns were personnel safety and procedure compliance
issues. The BGE practice of using gold cards to document some procedure
compliance and personnel safety concerns was considered poor and could prevent
proper resolution and tracking of the concern.
V. Manaaement Meetinos
X1
Exit Meeting Summary
During this inspection, periodic meetings were held with station management to
discuss inspection observations and findings. On June 19,1997, an exit meeting
was held to summarize the conclusions of the inspection. BGE management in
attendance acknowledged the findings presented.
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X2
Review of UFSAR Commitments
4
A recent discovery of a licensee operating its facility in a manner contrary to the
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Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a
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special focused review that compares plant practices, procedures and/or parameters
to the UFSAR description While performing the inspections discussed in this
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report, the inspectors reviewed the applicable portions of the UFSAR that related to
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the areas inspected to verify that the UFSAR wording was consistent with the
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observed plant practices, procedures and/or parameters. No discrepancies were
identified.
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ATTACHMENT 1
PARTIAL LIST OF PERSONS CONTACTED
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P. Katz, Plant General Manager
K. Cellers, Superintendent, Nuclear Maintenance
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K. Neitmann, Superintendent, Nuclear Operations
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P. Chabot, Manager, Nuclear Engineering -
T. Pritchett, Director, Nuclear Regulatory Matters
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B. Watson, General Supervisor, Radiation Safety
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C. Earls, General Supervisor, Chemistry
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L. Gibbs, Director, Nuclear Security
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T. Sydnor, General Supervisor, Plant Engineering
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T. Forgette, Director - Emergency Preparedness
G. Detter, Design Engineer
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S. Adams, Reactor Engineer, Region l
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INSPECTION PROCEDURES USED
IP 62707: Maintenance Observation
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IP 71707: Plant Operations
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IP 93702: Prompt Onsite Response to Events at Operating Power Reactors
IP 61726: Surveillance Observations
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IP 37550: Engineering
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IP 37551: Onsite Engineering
IP 71750: Plant Support Activities
IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring
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Attachment 1
2
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ITEMS OPENED, CLOSED, AND DISCUSSED
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OR2014
50-317&3i8/97-03-01
Multiple examples of failure to document and
report to management significant conditions
adverse to quality
Q!gsg_4
50-317/96-04-00
LER
Two ASI Channels OOS Due to Reversed Nuclear
Instrumentation Leads
50-317&318/96-06-02
Two ASI Channels OOS Due to Reversed Nuclear
instrumentation Leads
50-317/96-03
LER
Discovery of Holes in the Containment Sump
Screen to Field Run Tubing
Updated
50-317&318/96-06-03
Salt Water and Service Water Systems
Continued Operability
LIST OF ACRONYMS USED
ASI
Axial Symmetry Index
As Low As Reasonably Achievable
Root Cause Analysis
Updated Safety Analysis Report
IR
issue Report
American Society of Mechanical Engineers
Post-Accident Sample System
Unresolved item
As Low As is Reasonably Achievable
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High Efficiency Particulate
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High Pressure Safety injection
Offsite Dose Calculation Manual
Quality Assurance
Quality Control
Radiation Monitoring System
RP&C
Radiological Protection and Chemistry
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Spent Fuel Pool
Updated Final Safety Analysis Report
TS
Technical Specifications
Out of Service
Electronic Personal Dosimeter
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Attachment 1
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GOT
General Orientation Training
-NVLAP
National Voluntary Laboratory Accreditation Program
Radiologically Controlled Area
Radiclogical Protection
REMS
Real Time Exposure Management System
Thermoluminescent Dosimeter
Warehouse Management System
BIS
Business Information System
SRWHX
Service Water Heat Exchanger
Containment Air Cooler