IR 05000317/1988010

Insp Repts 50-317/88-10 & 50-318/88-11 on 880509-13. Violation Noted.Major Areas Inspected:Licensee Radiological Controls Program During Unit 1 Outage

ML20196D802
Person / Time
Site:	Calvert Cliffs
Issue date:	06/14/1988
From:	Gresick J, Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20196D785	List: IR 05000317/1988010 ML20196D781 ML20196D794
References
50-317-88-10, 50-318-88-11, NUDOCS 8807010466
Download: ML20196D802 (9)

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t U.S. NUCLEAR REGUL*.f0RY COMMISSION

REGION I

Report Nos s-317/88-10 50-318/88-11 ,

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Docket No License No DPR-53 Category C ' DPR-69 Licenste: Baltin; ore Gas and Electric Company P.O. Sox 1475 Baltimor,e, Maryland 21203 Facility Name: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection At: Lusby, Maryland Inspection Conducted: May 9-13, 1988 Inspectors: N.(XIb 6fl3 date E A. Weadock, Radiation Specialist ( (o fl E. E% J. Gresick, l' Jtation specialist date f Approved by:

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  / 977 . M M. Shanbaky, chief, Faciffties Radiation
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da~te __ rotection Sectica Inspection Summary: Inspection conducted on May 9-13, 1988 (Combined Inspection Report Nos. 50-317/88-10, 50 318/88-11). Areas InsSected: Routine, unannounced inspection of the licensee's Radiological controls >rogram during the Unit 1 outage. The following areas were reviewed: management organization and controls, external exposure controls, internal exposure controls, posting and labeling, and ALAR Results: One violation concerning a failure to follow procedures was identified and is discussed in section 5.0.

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, 8807010464 880621 !. PDR ADOCK 05000317 i Q DCD __ _ _ _ _

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DETAILS 1.0 Persons-Contacted L. Attis Bartlett Site Coordinator T. Goff Dosimetry Supervisor J. Lemons Manager, Nuclear Operations Dep *J. Lenhart Radiological Controls Operations Sup *N. Millis Radiation Safety General Sup *J. Osborne Licensing Engineer

 *G. Phair  Radiation Control ALARA Sup *E. Roach  Quality Assurance Auditor
 *E. Reimer  Plant Health Ph sicist D. Showalter Radiation Safet Instructor
 *L. Smialek  Radiation Contr 1 and Support Asst. Gen. Sup *A. Vogel  Technical Training Sup R. Wyvill  ALARA Coordinator
 * Attended the exit interview on May 13, 198 Other licensee personnel were also contacted during the course of this inspectio .0 Purpose Th. purpose of this routine, unannounced inspection was to review the imp ementation of the licensee's Radiological Safety Program during the

! Unit 1 outage. The following areas were included in this review:

 - management organization and controls / training,
 - external exposure controls,
 - internal exposure controls,
 - posting and labeling of radiological areas,
 - ALAR .0 Management Organization and Controls / Training The effectiveness of the licensee's Radiation Safety organization was evaluated by the following methods:

! - discussion with cognizant personnel, l - review of the following documentation: ! ! - Calvert Cliffs Instruction (CCI) 617, "Radiation Safety Section Training & Qualifications,"

 - Procedure RSP 1-112, "Special Maintenance Radiological Control Procedure,"
 - selected Radiation Safety Job Control Standards (JCS).

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Within the scope of the above review, no violations were identified. The current Unit 1 outage began on April 8, 1988, and is scheduled to continue until the end of May. The Unit 1 outage was preceeded by an approximately one month long maintenance outage at Unit 2. Approximately 50 contractor Senior Radiation Safety Technicians (RSTs) were brought in to support the outag NRC review of selected training records identified that contractor RSTs received site-specific procedural training in accordance with CCI 61 The licensee's outage organization was consistent with that spuified in procedure RSP 1-112. The following areas for licensee attention vere identified:

- The licensee has recently developed several Job Control Standards (JCSs)

to provide information to RSTs as to how specific job evolutions should be controlled and performed. This was noted as a positive incentiv Discussion with the RSTs identified, however, that there was an incomplete understanding as to the availability and the purpose of the JCSs among the technician The licensee attributed this to the recent development of the JCSs and indicated their existence and purpose would be appropriately communicated to the RST Prior to the outage the Radiation Safety staff shifted from providing a

"zone" type RST coverage for work to a one on one" method of RST coverag Licensee personnel indicated this shift was not communicated to the work groups prior to the outage and resulted in confusion at the onset of the outag A deficiency with contractor RST and support personnel training was identified and is discussed in section During the above review the inspector viewed a 12 minute training film routinely shown to workers receiving Radiation Safety training. The film follows a typical worker into the controlled area and was noted to be a positive training incentiv .0 External Exposure Controls The licensee's program for controlling external exposures during the refueling outage was evaluated by the following methods:
- discussions with cognizant personnel,
- observations of ongoing work activities, including steam genera n r (S/G)

and reactor coolant pump (RCP) maintenance,

- review of the following documentation:

o selected 1987 and 1988 personnel whole body exposure records, o procedure RSP l-201, "SWP Preparation," o procedure RSP 1-106, "Special Work Permit Administration,"

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o selected special work permits, ALARA reviews, and surveys associated with S/G and RCP maintenance, o selected applicable _ Job Control Standards (JCSs).

Within the scope of the above review, no violations were identifie Effective in-field controls were associated with the on-going S/G maintenance activity. Special Work Permits (SWPs) and associated surveys and ALARA reviews were adequate to support work activities. The S/G JCS (JCS-004) was extensive, and included protective clothing and shielding requirements and radwaste removal activities. It was noted, however,that this JCS did not clearly specify the location and type of air sampling required for this activity (see section 5.0).

The inspector also reviewed licensee JCSs applicable to radiological diving operations (JCS-018,-019). Prior to their recent development, the licensee had no formal procedure specific to radiological diving operation Development of these JCSs was therefore noted as a program improvemen The inspector noted, however InformationNotice(IN)84-61,thatnotallareasdiscussedinNRC"Overexposure of Dive Reactor Refueling Cavity," were included in the applicable JCSs.

, l These inc(PWR)d lude the positioning of the diver's entry area relative to the radiation source and the need to set responsibility for establishing water clarit The licensee indicated the subject JCSs would be reviewed against IN 84-61 to insure all appropriate guidance was includa .0 Internal Exposure Controls The licensee's program to control internal exposures was reviewed against criteria contained in: , l

 - 10 CFR 20.103, l  - Technical Specifications Section 6.11, "Radiation Protection Program,"
 -procedureRSPl-117,"Selection, Issuance,andWearingofRespiratory Protection Devices Used at Calvert Cliffs Nuclear Plant,"
 - NUREG-0041, "Hanual of Respiratory Protection Against Airborne Radioactive Materials."

The licensee's perfomance relative to these criteria was determined from:

 - discussions with cognizant personnel,
 - review of selected air-sampling logs
 - observations of in-field respirator issue, use, and air-samplina,
 - review of lesson plan RS-320-001-03, "Contractor Radiation Safefy Technician Watchstation Training."

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Within the scope of the above review, one apparent violation was identified and is discussed belo .1 Respiratory Protection Equipment Fit Test The licensee requires in RSP l-117 that respirator users perform an in the field positive pressure check, a negative pr'ssure check, and receive a stannic chloride or "smoke" test to verify acceptable respirator fit prior to use of equipment. Use of a stannic chloride smoke tube, which generates an irritant smoke, is recommended by NUREG-0041. As stannic chloride is an irritant, NUREG-0041 states that individuals receiving an irritant smoke test should be cautioned to keep their eyes closed and to breathe shallowly at the beginning of the test. Licensee procedure RSP l-117 was noted to incorporate this guidance as a procedural requirement in section 6.6, which states that "prior to testing the fit with the sm @ , caution the wearer to keep his eyes closed and to take shallow breaths."

who stated that on The inspector or about interviewed April 26, an individual 1988 he received (individual an accidental inha A)lation of stannic chloride while attempting to perform qualitative field fit testing of his respirator prior to entry to the Unit 1 Containmen Individual A stated he was experiencing a stuck open exhalation valve on his respirator and was trying to free it by taking deep breaths when the RST administered the smoke test to him using a stannic chloride smoke tube. Consequently, individual A stated he received a full, unfiltered inhalation of the irritant smoke. Both tne involved RST and individual A stated that no verbal caution or warning was given prior to administering the smoke tes Individual A stated he subse distress from this exposure.quently experienced significant medical Technical Specification (T.S.) section 6.11, "Radiation Protection Program" requires that procedures for personnel radiation )rotection shall be prepared consistent with the requirements of 10 C:R 20 and shall be adhered to for all operations involving personnel radiation exposure. Failure of the RST to provide the appropriate cautionary statements prior to irritant smoke testing as required by RSP 1-117 constitutes an apparent violation of T.S. section 6.11 (317/88-10-01; 318/88-11-01).

Subsequent to this incident, Individual A requested a waiver from the smoke testing requirement. This request was reviewed and disallowed by the Radiation Safety General Supervisor. The licensee performed an internal review of the event and identified the need for additional training for RSTs on the cautionary statement requirements of RSP 1-11 The licensee subsequently held a training briefing with the RSTs to emphasize the procedural requirement NRC review of in-field smoke tesiing practices during the week of the inspection identified that licensee corrective actions were ineffectiv The inspector observed two different individuals administering the smoke _____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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6 test to respirator wearers at the Unit 1 Containment access without giving the cautionary statments. The licensee subsequently identified that at least one of the individuals observed had not been present at the training briefing. The inspector also noted the individual running the respirator fit-test booth gave inappropriate statements ("take two deep breaths") while administering the smoke test prior to entry to the boot The inspector also identified a deficiency in the level of training provided to individuals performing smoke tests. Review of the RST lesson plan and discussion with the cognizant instructor identified this topic was discussed in RST training. RSTs interviewed by the inspector, however, could not recall a discussion of the need for providing cautionary statements in RST training. The inspector also noted the qualification card for the fit-test booth operator did not require review of procedure RSP l-11 The following concerns were also noted relative to in-field issue and use of respirator Sanitized respirators were staged in large, open carts in the hallway outside the respirator issue window. During periods when the issue window was unattended, both respirators and respirator issue forms were freely available to unauthorized worker Individuals performing' smoke tests at the Unit ! containment hatch were not observing workers as they donned respirators to verify workers were performing positive and negative pressure checks. The inspector observed several workers who did not perfore the positive pressure chec The licensee indicated the above areas would be evaluated. The licensee also stated that they had experienced no problems with the use of respirators by unauthorized personne .2 Air Sampling Program The inspector observed air sampling activities to su) port S/G maintenance and tube-plugging activities. The inspector noted tlat an air sample was obtained in the general area of the work platform, rather than in the S/G channelhead itself, during personnel entry to the channelhead for tube-plugging. A review of the applicable JCS identified that specific direction as to location, etc. is not given for air-sampling with the same degree of detail as other radiation safety aspects of the job. The inspector discussed air sampling practices with the licensee who stated that numerous channelhead air samples had been taken during the outage and air activity in the channelhead had been established. The licensee also stated that air sampling requirements during steam generator entry would be given more detail in the JCS to ensure appropriate breathing zone samples were take .

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6.0 Posting and Labeling / Contamination Control The licensee's program for the posting, labeling, and control of radiological areas and radioactive material was evaluated by the following methods:

 - discussion with cognizant personnel,
 - tour of various radiological work areas, including the Auxiliary Building and the Unit 1 containment,
 - performance of independent surveys,
 - review of the following procedures:

o RSP l-104, "Area Posting and Barricading," o RSP l-105, "Small Radioactive Particle Control."

' Radiological posting and housekeeping conditions in the Auxiliary Building were noted to have improved since the previous inspection with the following exception. On May 11, 1988, the inspector noted a work party in the Unit 1 VCT room on the 5 foot elevation of the Auxiliar The room was )osted with signs indicating "High Radiation Area"y andBuildin "Gamma Exposure late Meter Required." Licensee T.S. section 6.12 requires that individuals entering a High Radiation Area (HRA) be provided with a radiation survey meter. The inspector noted the work group did not have a surve meter and that the SWP for the work (SWP 1607) did not specify work in a R Subsequent NRC survey identified a HRA did not exist in the Unit 1 VCT room and consequently no violation of HRA control requirements had occurre The licensee stated the VCT room was not a HRA during outage conditions and that although controls over the area had been relaxed, room posting had not been downgraded to reflect area status. The licensee subsequently modified the posting for the roo The licensee approved procedure RSP l-105 during the week of the ! inspection. Small Radioactive Particle place to support work around the spent el fu(SRP) pool andcontrols werecavit the refueling noted to be in SRP controls included the use of additional protective clothing, stay time controls, and the use of special survey techniques to identify SRPs. The inspector noted that although survey frequencies inside known SRP areas were established, no instruction or frequency was included in RSP l-105 as to performance of SRP surveys in the "buffer zone" around SRP areas. The licensee indicated the need for this instruction would be evaluate The licensee first identified SRPs during the Unit 2 maintenance outag SRPs were also identified in association with fuel reconstitution activities at Unit 1. The majority of SRPs were found during surveys or on . individual's clothing. Maximum skin dose resulting from particle skin l contaminations was less than 1 Rad. Licensee skin dose calculational ' methodology was not reviewed during this inspection.

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7.0 ALARA The licensee's program for maintaining occupational exposures ALARA was reviewed by the,following methods:

 - discussion with cognizant personnel,
 - observation of ongoing radiological work activities,
 - review of site exposure goals,
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 - review of selected ALARA estimates and review Within the scope of the above review, no violations were identified. The overall 1988 site goal is 320 person-rem, with a Unit 1 outage goal of 210 person-rem. As of May 9, 1988, total site exposure was approximately 186 person-rem, with 118 person-rem attributable to the Unit 1 outage. The licensee stated that final outage exposure was anticipated to be within the outage goa The following licensee strengths were noted in th!: review:
 -- exposure estimates daily exposure for various tracking jobswas and review werebeing competitive,d performe by the ALARA staff,
 - the licensee's post-job ALARA review process has the option to generate
 "open-items" based on lessons-learned which require formal response from the receiving work group
 - the ALARA staff was cognizant of jobs that had already come in over their estimate and was developing lessons-learaed,
 - the licer n was using effective exposure-saving devices including CCTV to view .,f d and containment maintenance activities, remote S/G ECT and tube plugging, and a WEPA machine for cavity decon.

j The following areas were noted for additional licensee improvemen Outage ALARA planning was delayed due to the prior Unit 2 maintenance outage. The actual outage exposure estimate, calculated by adding all specific job estimates, was not completed until April 25, 1988.

( - Specific jobs were noted which went over budget due to poor communications relative to the workscope (pressurizer doghouse insulation or due to use of inexperienced personnel (reactor vessel head placement)). The licensee indicated planning for the next outage would be improved as the impact of a mini-maintenance outage would be better anticipated.

l The inspector noted that, other than the above minor areas for improvement, the Calvert Cliffs ALARA program is continuing to be implemented effectively.

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8.0 : Exit Meeting The inspector met with licensee. representatives, denoted in Section 1.0 of the report, on May 13, 1988. The ins scope and findings of the inspection.pector summarized the purpose of, i l .

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