ML20217F148

Insp Repts 50-317/97-08 & 50-318/97-08 on 971221-980207. Violations Noted.Major Areas Inspected:Operations,Maint, Plant Support & Results of Specialist Insps in Emergency Planning & Security

ML20217F148
Person / Time
Site:	Calvert Cliffs
Issue date:	03/20/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20217F131	List: ML20217F125 ML20217F142 ML20217F148
References
50-317-97-08, 50-317-97-8, 50-318-97-08, 50-318-97-8, NUDOCS 9803310290
Download: ML20217F148 (45)

See also: IR 05000317/1997008

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U.S. NUCLEAR REGULATORY COMMISSION

REGION 1

License Nos. DPR-53/DPR 69

Report Nos. 50-317/97-08 & 50-318/97-08

Licensee: Baltimore Gas and Electric Company

Post Office Box 1475

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: December 21,1997 through February 7,1998

Inspectors: J. Scott Stewart, Senior Resident inspector

Fred L. Bower Ill, Resident Inspector

Henry K. Lathrop, Resident inspector

William Maier, Emergency Preparedness Specialist

Edward King, Physical Security inspector

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Approved by: Lawrence T. Doerflein, Chief

Projects Branch 1

Division of Reactor Projects

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9803310290 980320

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ADOCK 05000317

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EXECUTIVE SUMMARY

Calvert Cliffs Nuclear Power Plant, Units 1 and 2

Inspection Report Nos. 50-317/97-08and 50-318/97-08

This integrated inspection report includes aspects of BGE operations, maintenance, and

plant support. The report covers a seven week period of resident inspection and the

results of specialist inspections in emergency planning and security.

Plant Operations

The inspectors conducted frequent reviews of control roorn operations and observed that

the control room operators were attentive and responsive to plant conditions, and

knowledgeable of the status of annunciators. Safety and risk significant systems and

support systems were observed to be appropriately aligned during periodic main control

panel walkdowns. Control room operators demonstrated appropriate use of self-checking,

peer checking, and three-way communication techniques.

The inspectors concluded that BGE was slow to recognize that the secondary control

element assembly (CEA) indication system was inoperable, the plant had operated outside

technical specifications, and that this event was reportable. This was determined to be a

violation of NRC requirements (VIO 50-317/97-08-02). Recent unreliability of the primary

CEA indication system contributed to BGE's difficulty in determining which CEA indication

system was inoperable.

Two examples of BGE's failure to develop adequate test procedures to ensure the

operability of the CEA secondary position indicating systems viere identified. This was

also determined to be a violation of NRC requirements (VIO 50-317&318/97-08-01).

When the secondary position indicating system was replaced during the 1994 Unit 1

refueling outage, BGE's design control measures did not identify the need to change the

variable power supply voltage and revise the applicable plant procedures and drawings. l

This was treated as a Non-Cited Violation (NCV 50-317&318/97-08-03).

The inspectors concluded that the non-licensed plant operators observed during two plant

tours were experienced and knowledgeable. BGE established processes for problem

identification, communications, and procedure adherence were wellimplemented.

Maintenance

The observed maintenance was conducted safely and in accordance with BGE approved

procedures and controls. Workers were knowledgeable and performed work effectively.

Quality verification personnel provided effective oversight of selected maintenance jobs.

The observed surveillances were conducted safely and effectively demonstrated system

operability. Thorough and detailed pre-test briefings were a strength of the surveillance

testing observed.

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Executive Summary (cont'd)

Plant Suonort

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[' .The BGE Self-Assessment of compliance with Appendix R to 10 CFR 50 was found to be a

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. good initiative and valuable tool for identifying areas for improvement. The results of the

assessment will remain unresolved pending further NRC review of the specific issues and

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corrective actions taken.

l A review of the fire protection program found excellent procedural guidance for the

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conduct of fire protection activities, an effective penetration seal program, appropriate

control of fire brigade qualification, effective audits for identifying problems and initiating

corrective actions, and good control of combustible materials.

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Overall, the emergency preparednesss (EP) facilities, equipment, supplies and

- instrumentation were being adequately maintained. Facility inventory verifications were

! adequately performed. BGE's changes to the Emergency Response Plan and Emergency ,

j Response Plan implementing Procedures were made in accordance with 550.54(q) of NRC

l regulations.

The emergency planning training program implementation meets the requirements of the

emergency response plan, the emergency response plan implementing procedures and the

Emergency Response Training Program Manual. The qualifications of Emergency Response

l Organization members were being tracked. Continuing emergency response training is

l provided by the individual site departments. However, there was weak central oversight of

L emergency planning training activities. Continuing training exams may cosa, a broad range

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of department specific topics and may not adequately examine knowledge of emergency

planning concepts.

f Communication circuit testing was in violation of NRC requirements from September 1996

! through September 1997 (VIO 50-317&318/97-08-05). The corrective actions which

j were taken prior to the inspection exit interview and which were presented in an meeting

at the Region I offices on February 2,1998, were adequate in response to this violation.

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Two .on-shift chemistry technicians were unable to correctly interpret the significance of

simulated radiation readings for assuming the level of core damage in table top

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walkthroughs. They did not follow their procedure when they failed to consult with the l

interim Site Emergency Coordinator to develop this assumption (VIO 50-317&318/97-08-

06). The inspectors noted that this training deficiency was similar to the exercise

weakness observed in NRC Inspection Report 97-09. Due to the repetitive nature of this

deficiency, these examples were cited as a violation of NRC requirements.

Senior site management is adequately involved in and informed about Emergency Planning

Unit (EPU) activities. The inspectors concluded that the two most recent Nuclear

Performance Assessment Department audits met all regulatory requirements. The 1997

audit report was thorough and detailed and was more detailed than previous audit reports, f

BGE's self-assessment program, with 127 self-assessments initiated in calendar year 1997,

was a good initiative.

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Executive Summary (cont'd)

BGE was effectively maintaining and competently administrating the security program.

Alarm station operators were knowledgeable of their duties and responsibilities, and

communications requirements were being performed in accordance with the NRC-approved

physical security plan. Security training was being performed in accordance with the NRC-

approved training and qualification T&Q plan.

Security equipment was being properly tested and maintained as evidenced by minimal

compensatory posting. Assessment aids had good picture quality and excellent zone

overlap. Detection aids were functional, affective ano met regulatory requirements.

The access authorization program was being implemented in accordance with regulatory

requirements, and personnel and packages were being properly searched prior to granting

protected area (PA) access. Interviews with Nuclear Security Officers, inspector

observations, and procedural reviews determined that visitor access was being controlled

and maintained as required.

Security audits were thorough and in-depth. Effective controls were in place for

identifying, resolving, and preventing programmatic security problems. These controls  ;

included an effective departmental self-assessment program.

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TABLE OF CONTENTS

E X EC UTIVE SU M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . il

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TA BLE O F C O NT E NTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

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Summary of Plant Status ..... ......................................1

1. O pe r at io n s - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

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01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

01.1 General Comments (71707) ...........................1

01.2 Operability of Control Element Assembly Position Indication . . . . . 2

O2 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . 5

l 02.1 Observation of Auxiliary Operator Rounds . . . . . . . . . . . . . . . . . . 5

ll . M ainte n a nce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

l M1.1 General Comme nts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . 7

! l il . Pl a nt Su pport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

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F1 Control of Fire Protection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

l F1.1 Control of Combustibles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 I

l F2 Status of Fire Protection Facilities and Equipment '. . . . . . . . . . . . . . . . . 8 l

F2.1 Fire Suppression System Walkdown . . . . . . . . . . . . . . . . . . . . . . 8

F2.2 Fire Barrier Penetration Seals . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 i

F3 Fire Protection Procedures and Documentation . . . . . . . . . . . . . . . . . . 10 l

F3.1 Fire Protection Program procedure . . . . . . . . . . . . . . . . . . . . . . 10

F5 Fire Protection Staff Training and Qualification . . . . . . . . . . . . . . . . . . 11

FS.1 Fire Brigade 1 raining Records .........................11

F7 Quality Assurance in Fire Protection Activities ..................12

l F7.1 Quality Assurance Audits of Fire Protection Program . . . . . . . . . 12

l F8 Miscellaneous Fire Protection Activities . . . . . . . . . . . . . . . . . . . . . . . 13

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F8.1 BGE Self-Assessment of Compliance with Appendix R to

10 CFR 50 ......................................13

, F8.2 (Closed) Violation 50-317&318/97-05-04, Emergency Lighting

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! P1 Conduct of EP Activities . ................................15

l P2 Status of EP Facilities, Equipment, and Resources . . . . . . . . . . . . . . . . 15

l P3 EP Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

l P5 Staff Training and Qualification in EP . . . . . . . . . . . . . . . . . . . . . . . . . 20

j- P6 EP Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . 21

i P7 Quality Assurance in EP Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

l P8 Miscellaneous EP issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

P8.1 (Closed): Unresolved item 50-317&318/96-06-04. . . . . . . . . . . 23

S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . 24

S2 Status of Security Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . 25

S3 Security cnd Safeguards Procedures and Documentation . . . . . . . . . . . 26

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Table of Contents (cont'd)

S4 Security and Safeguards Staff Knowledge and Performance . . . . . . . . . 26

SS Security and Safeguards Staff Training and Qualification (T&O) ......27

S6 Security Organization and Administration . . . . . . . . . . . . . . . . . . . . . . 27

l S7 Quality Assurance (QA) in Security and Safeguards Activitics . . . . . . . . 28  ;

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V. M anagem ent Meeting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 9

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l X1 Review of UFSAR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

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X2 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

X3 Management Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

ATTACHMENTS

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l Attachment 1: Partial List of Persons Contacted

Inspection Procedures Used

Items Opened, Closed and Discussed

List of Acronyms Used

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Attachment 2: Fire Barrier Penetration Seals Inspected and Drawings Referenced

Attachment 3: Emergency Response Plan and Implementing )

l Procedures Reviewed '

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Report Details

Summarv of Plant Status

Unit 1 began the inspection report period at full power. Power was reduced to

approximately 97 percent on January 2 and was returned to full power on January 4 after

the completion of planned moderator temperature coefficient surveillance testing. On

January 13, BGE initiated a plant shutdown in accordance with technical specification (TS)

3.0.3 when the both low pressure safety injection headers were determined to be

inoperable due to a cracked weld on a seismic restraint in the common discharge header.

Power was reduced to 98 percent before the systems were restored to an operable status.

Power was reduced to approximately 85 percent for scheduled maintenance on January 30

and was returned to full power on January 31.

Unit 2 also began the inspection report period at full power. Power was briefly reduced to '

99.5 percent after securing a heater drain pump in response to a level control valve failure. *

Unit 2 was operated at full power for the remainder of the inspection report period.

I. Operations

01 Conduct of Operations

01.1 General Comments (71707)

Plant operations were conducted safely with a proper focus on nuclear safety. On

January 13, during the inspection of the common low pressure safety injection (LPSI)

discharge line, engineering ' personnel identified a crack in the weld between a pipe support

stanchion and the LPSI piping. Identification of this problem was not immediately

communicated to Operations personnel. After notification of this problem approximately 3

hours later, Operations declared both LPSI headers inoperable. A unit shutdown was

commenced in accordance with the requirements of TS 3.0.3. BGE removed the support

with a temporary alteration at:d performed an engineering evaluation to support operability.

The plant was subsequently returned to full power. An NRC engineering inspection team

was onsite during this period and reviewed this issue. The details of engineering team's

review will be documented in NRC Inspection Report 50-317&318/98-80.

Using inspection Procedure 71707, " Plant Operations," the inspectors conducted frequent

reviews of control room operations. In general, the conduct of operations was professional

and safety conscious. The control room operators were attentive and responsive to plant

conditions. Control panels were periodically walked down and safety and risk significant

systems and support systems were observed to be appropriately aligned. During the

inspection period, control room operators were knowledgeable of the status of

annunciators. Control room operators demonstrated appropriate use of self-checking, peer

checking, and three-way communication techniques.

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01.2 Operability of Control Element Assembly Position Indication

a. J.nsoection Scope

The inspectors reviewed the problems with the control element assembly (CEA)

position indication systems.

b. Dbservations and Findinas

On January.4, Unit 1 was operating at 97 percent power with the group 5 CEAs

partially inserted for moderator temperature coefficient testing (MTC). During the

MTC testing, a CEA motion inhibit alarm was received. The operators determined-

that the pulse counting (primary) and voltage divider reed switch (secondary) CEA

position indications deviated from each other by 5 to 6 inches for all the group 5

CEAs. The tertiary indication, the " full out" reed switch position indication, was

not operable with the CEAs partially inserted. The operators determined that the

position indicating systems did not meet the TS requirement for two of the three

position indication systems to agree within 4.5 inches.

The operators investigated the problem and reviewed the issue with nuclear fuels

and systems engineering personnel. Recently the primary position indicating i

system has been unreliable. The Unit 1 CEAs have been maintained at the " full I

out" position in lieu of the normal 132 inch position due to this system

- unreliability. BGE had identified computer cards that required replacement to

improve the system reliability; however, this corrective action had not been

completed prior to the Unit 1 MTC testing. Additionally, BGE had considered the

secondary indication more accurate than the primary indication since the

secondary indication determines position from reed switches spaced along the

CEA housing whereas the primary indication infers position from counting pulses

sent to the CEA magnetic jack mechanism. The operators concluded that the

primary indication system was inoperable based on the results of their

investigations, the system's accuracy and unreliability, and consultation with

engineering personnel.

The operators promptly entered TS action 3.1.3.3.b, which allows continued

operation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with the primary position indication system and one of the

remaining position indication systems inoperable. BGE personnel completed the

MTC testing and proceeded to return the CEAs to the " full out" position. This

action was completed, on January 5, within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time allowed by the TS

action statement. The deviation between the primary and secondary position

indicating systems narrowed to approximately three inches, but remained until the

CEAs reached " full out" indication on the tertiary indication. The TS action

statement was exited when the " full out" indication became operable.

Subsequent information indicated all of the CEAs in group 5 were maintained

within 7.5 inches of each other as required by technical specifications. Therefore,

this event was of low safety significance since assumed values for peaking

factors, power distribution and shutdown margin were not exceeded by

maintaining the CEA deviation within TS limits.

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On January 5, the inspectors observed that instrument maintenance technicians

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were performing troubleshooting and adjusting the power supply voltage to the '

secondary position indication system voltage divider. The voltage had drifted from

the setting specified in a once per refuel cycle instrument maintenance procedure j

for aligning the CEA position indicating system. The inspectors questioned why j

troubleshooting was being performed on the secondary system when the primary '

system had previously been identified as the inoperable system. The inspectors

further noted that no specific TS action existed for the previous simultaneous l

inoperability of the secondary position indication and the " full out" indication. The ;

inspectors questioned whether the plant was operated outside of technical

specifications since TS 3.0.3 had not been entered on January 4. BGE personnel

indicated that investigations and troubleshooting were ongoing.

On January 6, the inspectors discussed the secondary position indication j

troubleshooting plan development with system engineering and instrument j

maintenance personnel. These personnelindicated that a three inch deviation

would still remain if the CEAs were reinserted. For example, if the rods were l

reinserted from the " full out" position of 135 inches, the secondary would not I

indicate that the CEAs were moving until they were inserted below 132 inches.

The deviation was suspected to have resulted from incorrectly setting the voltage  !

for the variable power supply to the secondary position indicating system. The

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BGE personnel believed that the voltage setting had been incorrect and undetected i

since the system was modified in 1994 to install a new viewing screen that

applied a smaller resistance to the voltage divider network. BGE personnel also  !

identified that there was no periodic surveillance test of this power supply voltage I

setting that was critical to the accuracy of the secondary position indicating

system. BGE personnel indicated that this issue would be reviewed for generic

implications. Failure to establish a test procedure to verify that the voltage divider

network power supply voltage was at the acceptance limit specified by the

applicable design documents is the first example of a violation of 10 CFR 50,

Appendix B, Criterion XI, " Test Control" (VIO 50-317&318/97-08-01),

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Technical Specification Limiting Condition for Operation (LCO) 3.1.3.3 requires the

CEA voltage divider reed switch position indication channel to be capable of j

determining the absolute CEA position within 1.75 inches. With three inches of

suspected deviation between the primary and secondary, the inspectors

questioned whether TS LCO 3.1.3.3 was being met. Operations personnel stated

that all the position indicating systems met this requirement at the " full out"

position. However, the inspectors commented that the system must be able to

meet the TS LCO and perform its design function throughout the full travel of the

CEA.

BGE assembled a cross section of plant operations, maintenance, and engineering

personnel to discuss and finalize a troubleshooting and repair plan for the

secondary CEA position indicating system. These personnel concluded that the

secondary indicating system was not capable of determining CEA position within

1.75 inches and was therefore not operable. The secondary indicating system had

not been operable since January 4. After declaring the secondary position

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indicating system inoperable, BGE promptly increased the surveillance of CEA

position from every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required by TS surveillance

requirements 4.1.3.1.1,4.1.3.3.2, and 4.1.3.6 The increased surveillances were

required since the deviation circuit, CEA motion inhibit, and power dependent

insertion limit alarm functions were also rendered inoperable. BGE personnel also

concluded that Unit 1 had been operated outside TS on January 4 when both the I

secondary position indication and the " full out" indication were simultaneously

inoperable. This was a violation of NRC requirements (VIO 50-317/97-08-02).

BGE personnel concluded that the deviation resulted from a combination of an

incorrect setting and a drift in the setting of the voltage for the variable power

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supply to the secondary position indicating system. During the 1994 Unit 1

refueling outage (and 1995 for Unit 2), the secondary position indicating system ,

was replaced with a CEA voltage divider position indication system which has a l

lower voltage resistance load. At that time, BGE's design control measures did not

identify the need to change the variable power supply voltage and revise the  ;

l applicable plant procedures and drawings. This non-repetitive, licensee-identified

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l and corrected violation is being treated as a Non-Cited Violation, consistent with {

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Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-317&318/97-08-03).

On January 6, BGE personnel calculated a new voltage setting for the Unit 1

variable power supply. The troubleshooting included adjusting the voltage to the

i new setting and testing the secondary position indicating system to ensure that j

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the system was then accurate to within the LCO specifications. This new voltage

setting was then made permanent. The troubleshooting was subsequently

extended to Unit 2 to determine if a generic concern existed. The Unit 2 CEAs

were located at their normal partially inserted position of 132 inches. No

significant deviation between position indicating systems was observed. BGE

troubleshooting determined that the variable power supply for the Unit 2 CEA

position indicating system had drifted down to a value approximately equal to the

new permanent voltage setting. The power supply was reset and the system was

satisf actorily tested.

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determined no surveillance test existed to verify the TS 3.1.3.3 LCO requirement

for the CEA voltage divider reed switch position indication channel to be capable of

determining the absolute CEA position within i 1.75 inches. BGE personnel

identified that there may be additionalinstances where TS surveillance alone are

not sufficient to verify that LCO requirements are met and no additional  :

surveillance test exists. BGE personnel submitted an issue report to the corrective  !

action system to investigate this issue further. This review was not completed

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during the inspection period. Failure to establish a test procedure to verify that the

CEA voltage divider reed switch position indication channel was capable of i

determining the design acceptance limit of absolute CEA position is the second  !

example of a violation of 10 CFR 50, Appendix B, Criterion XI, " Test Control" (VIO  !

50-317&318/97-08-01). '

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The inspectors reviewed the updated final safety analysis report (UFSAR) and

noted that. UFSAR figure 7-12 also indicates that the setpoint for the upper

electrical limit or the " full out" position was at 136 inches. Additionally, the

Operating Ir;structions specify aligning the primary CEA position indicating system

to 135 inches when the CEAs are at the " full out" position. This figure was

discussed with BGE personnel who stated that the " full out" position was actually

located at between 135 and 135.75 inches. BGE personnel initiated an issue

report to investigate and resolve these apparent conflicts. This issue is discussed

further in Report Section X.1.

c. Conclusions

During CEA manipulations for MTC testing the primary and secondary CEA position

indications for all the group 5 CEAs deviated from each other by more than

allowed by technical specifications. The tertiary indication, the " full out" reed

switch position indication, was not operable with the CEAs partially inserted. The i

inspectors concluded that BGE was slow to recognize that the secondary CEA '

indication system was inoperable, the plant had operated outside technical

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specifications, and that this event was reportable. This was determined to be a

violation of NRC requirements (VIO 50-317/97-08-02). Recent unreliability of the

primary CEA indication system contributed to the BGE's difficulty in determining

which CEA indication system was inoperable.

Two examples of BGE's failure to develop adequate test procedures to ensure the

operability of the CEA secondary position indicating systems were identified. The

NRC inspectors identified one example. This was also determined to be a violation

of NRC requirements (VIO 50-317&318/97-08-01). BGE personnel identified that

the inoperability of the secondary position indicating system resulted from a

combination of an incorrect setting and a drift in the setting of the voltage for the

variable power supply to the secondary position indicating system. When the l

secondary position indicating system was replaced during the 1994 Unit 1

refueling outage, BGE's design control measures did not identify the need to

change the variable power supply voltage and revise the applicable plant

procedures and drawings. This was treated as a Non-Cited Violation (NCV 50-

317&318/97-08-03). However, throughout this event, all of the CEAs in group 5

were maintained within 7.5 inches of each other as required by technical i

specifications. Therefore, this event was of low safety significance since assumed

values for peaking factors, power distribution and shutdown margin were not

exceeded by maintaining the CEA deviation within TS limits.

02 Operator Knowledge and Performance

O2.1 Observation of Auxiliary Operator Rounds

a. Inspection Scope (71707)

The inspectors observed non-licensed nuclear plant operators (NPOs) conduct tours

of the Unit 1 auxiliary and turbine buildings.

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b. Observations and Findinos

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The inspectors noted that the NPOs were experienced, and knowledgeable of their

duties and plant equipment for the areas assigned. The NPOs identified several

deficiencies during the plant tours. The control room was promptly notified of out-

of-specification readings and local alarms. Three-way communication techniques

were implemented. The NPOs initiated issue Reports (IR) to enter the minor

deficiencies into the corrective action program. The inspectors noted that the

NPOs used appropriate personal and radiation safety techniques. Applicable

procedures, including " memory use" procedures were brought to the operating

stations and followed step-by-step.

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c. Conclusions

The inspectors concluded that the non-licensed plant operators observed during

two plant tours were experienced and knowledgeable. BGE established processes

for problem identification, communications, and procedure adherence were well

implemented.

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11. Maintenance

l M1 Conduct of Maintenance

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M1.1 General Comments

a. Inspection Scoos (627_QZ)

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The inspectors reviewed maintenance activities and focused on the status of work

that involved systems and components important to safety. Component f ailures

or system problems that affected systems included in the BGE maintenance rule

program were assessed to determine if the maintenance was effective. Also, the

inspectors directly observed all or portions of the following work activities:

IR3-OO2-228 22 Component Cooling HX Outlet Gage Calibration

IR3-OO3 684 2B Emergency Diesel Speed Switch Adapter Replacement

M0119980010.5 Remove SG Blowdown Piping and Hand Valve 104

l M01199800117 Replace 2" SG Blowdown Piping and Valve

l MO1199800006 CEAPDS Position Indication Troubleshooting

MO1199705396 Leak Repair Unit 1 HP Turbine

b. Obseivations and Findinos

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l The inspectors found that tt e selected maintenance activities were performed

safely and in accordance with approved procedures. Technicians were

experienced and knowledgeable of the assigned duties. Pre-job briefings were

effective in ensuring that the work was conducted in accordance with BGE work

protocols and plans. The work instructions provided in the maintenance order

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l packages were adequate in scope and detail. Additions and changes to the

! maintenance work order instructions were properly documented and approved.

l When applicable, appropriate radiation control measuras were in place and foreign

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material exclusion controls were practiced. The inspectors noted that an

I appropriate level of supervisory attention was given to the work. Quality

l verification personnel were seen providing effective oversight for some

maintenance work observed.

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c. Conclusions

The observed maintenance was conducted safely and in accordance with BGE

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approved procedures and controls. Workers were knowledgeable and performed

work effectively. Quality verification personnel provided effective oversight of ,

selected maintenance jobs. f

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M1.2 Routine Surveillance Observations

a. Insoection Scooe (61726)

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

l STP-O-73D-1 Charging Pump Performance Test

l STP-O-73A-1 Saltwater Pump and Check Valve Quarterly Operability Test

STP-O-29-1 Monthly CEA Partial Movement Test

STP-O-8 A-1 1 A EDG and 114Kv Bus Testing

b. Findinas and Observations

The pre-test briefings performed by the control room operators were detailed and

thorough. Pre-test briefings included review of procedural steps, special

precautions, means of communication, special test equipment, and contingency

actions. As applicabic, past problems experienced during the performance of the

tests were discussed. Excellent questioning attitudes were displayed during the

pre-test briefs and all questions were satisfactorily resolved prior to commencing

the test evolutions. The observed surveillance testing was performed safely and in

accordance with approved procedures. The inspectors observed that an

appropriate level of supervisory attention was given to the testing including direct

observation of test steps. The test equipment used met procedure and calibration

requirements. The inspectors observed that the details of the approved procedures

in use were clear and technically adequate. The inspectors noted that the testing

was performed by qualified personnel, and the test results satisfied the acceptance

criteria.

( c. Conclusions

The observed surveillances were conducted safely and effectively demonstrated

system operability. Thorough and detailed pre-test briefings personnel have

continue to be a strength of the surveillance testing observed,

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111. Plant Support

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F1 Control of Fire Protection Activities

F1.1 Control of Combustibled

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a. Inspection Scope

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The inspector reviewed Section 5.2, " Controlling Transient Combustibles," of

procedure SA-1-100, Rev. 4, " Fire Prevention," and observed the in-plant

conditions during plant tours.

b. Observations and Findinas

The controls in SA-1-100, Section 5.2 required no special controls of transient l

combustibles in an area that are less than that amount assumed present in the

Combustible Loading Analysis. Should the transient combustible loading exceed

that amount, the job supervisor was responsible for obtaining guidance from the

fire protection engineer (FPE), and implementing any additional measures specified

by the FPE.

During tours of the tacility, the inspector did not observe accumulations of '

l combustible materials in the plant. In addition, the gas cylinder storage cages,

located outdoors, at the south-east corner of the services building, maintained i

25 feet separation between oxygen and fuel cylinders.

c. Conclusions

The inspector determined that there was good control of combustible materials and

oxidizers, and that housekeeping in the plant was excellent.

F2 Status of Fire Protection Facilities and Equipment

F2.1 Fire Sucoression System Walkdown

)

a. Inspection Scope

The inspector conducted a walkdown of the Unit 2 Service Water Pump room

Sprinkler System (Sprinkler System 205),in company of the Fire Protection

Engineer (FPE). The inspector also reviewed Drawing No. 12261-28, Sheet 7,

Rev.11, "Calvert Cliffs Nuclear Plant, Lusby, Maryland, Unit 2 - Elev. 5'-0"," the

Automatic Sprinkler Corporation of America (ASCOA) design drawing, and

Drawing 60714SH0003,Rev. 24, " Plant Fire Protection System, Turbine and

Service Bldgs. & Intake Structure," the fire protection water system piping and

instrumentation drawing (P&lD).

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b. Observations and Findinas

The Unit 2 Service Water pump room was served by a wet pipe sprinkler system,

with local and remote alarms. The system was designed by ASCOA based on

. hydraulic calculations. Local alarm was provided by a water driven bell. During

l- the walkdown, the inspector observed that the pipiag was in good repair, and

! conformed to the design configuration. In addition, the sprinkler heads were of the

l type, and in the locations and orientations, specified by the ASCOA design. _The

{: FPE pointed out to the inspector the location where a sprinkler head had been

l removed after obtaining certification of the room's watertight door for a fire barrier

l. door. This was performed to ease moving equipment into and out of the room,

! without the need to disable the sprinkler system for removal of the sprinkler head.

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c. Conclusions

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] Based upon the observed condition of the Unit 2 Service Water pump room

i sprinkler system and a review of the design drawings, the inspector concluded that

the system was in conformance with its design, and was in good condition.

F2.2 Fire Barrier Penetration Seals

a. Inspection Scone

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The inspector, in company of the FPE, performed an inspection of fire barrier

penetration seals between the Unit 2 45'switchgear room and the Unit 2 B cable

chase. The specific penetrations inspected are listed in Attachment 2 to this  ;

j report. The inspector also reviewed the drawings listed in Attachment 2 to  !

j determine the design of the seals which should be present. The inspector also

reviewed Section 5.4, " Controlling Fire Barrier Penetrations," of procedure SA-1-  ;

100, Rev. 4, " Fire Prevention."  !

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b. Observations and Findinas i

The fire barrier penetrations at Calvert Cliffs Nuclear Power Plant (CCNPP) used  !

grout to seal the blockout around the original cable trays and conduits. The areas  :

, inside the cable trays were sealed using a packing of ceramic fiber, and a covering  !

l of flamemastic at both ends of tne penetration. Seals were required to be flush l

! with the face of the barrier, or not more then six inches from the face of the

barrier. For those cases where shrinkage of the grout, or sagging of the metal l

covers of the cable tray has created a gap, the gap is sealed using a nominal 3"

ceramic fiber and %" of approved silicone sealant. For new installations, the

space between the blockout and the penetrant may be scaled with room

temperature vulcanizing (RTV) silicone foam. The need for internal conduit seals

was based on the specifics of the conduit (size, cable fill, distance of termination

from barrier) and where an enclosure was considered part of the conduit run, the

enclosure must be so marked.

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The cable tray penetrations between the Unit 2 45' elevation switchgear room and

the Unit 2 B cable chase all used ceramic fiber (kaowool) and flamastic to seal the

tray interior. The inspector observed that both sides of the penetrations were

sealed. Penetration 2-BARR 2B/407-TOOO2showed evidence of having been

disturbed on the cable chase side. It was apparent to the inspector that the

flamastic had been reapplied at one place on the face of the seal. The FPE

indicated that this was a repair after installing a new cable.

All the conduits inspected were appropriately plugged at the wall, or extended

beyond the qualified minimum length, and the enclosures (junction boxes and

condulets) were marked as part of the qualified penetration barrier.

Section 5.4 of procedure SA-1-100 permits temporary seals to be installed during

the conduct of modification work. The opening must be packed with ceramic  :

fiber, and an impairment must be processed, and compensatory actions specified

by the FPE in place for the duration of the temporary seal.

c. Conclusions

Based upon the observed condition of the fire barrier penetration seals, and a

review of the design documents and procedural controls, the inspector concluded

that the penetration seal program has been effective in maintaining the integrity of

the fire barrier penetration seals.

F3 Fire Protection Procedures and Documentation

F3.1 Fire Protection Proaram orocedure

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a. Inspection Scone 1

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The inspector performed a review of procedures SA-1, Rev. 2, " Fire Protection i

Program," and SA-1-100, Rev. 4, " Fire Prevention," in their entirety, to determine

what administrative controls have been imposed on plant activities to control the

risk of fires.  ;

b. Observations and Findinos

Procedure SA-1, " Fire Protection Program," provided the general requirements, and

assigns responsibilities for the CCNPP fire protection program. Procedure SA-1-

100, " Fire Prevention," provided all the specific guidance for the various functions -  !

of the fire protection program. All facets of the program were covered in the

single procedure, with specific guidance for compensatory measures when

impairments were identified or planned. For planned impairments (such as  !

breaching a fire wall, disabling a suppression system, bringing in transient

combustibles), compensatory actions were required to be in place prior to the ,

impairment being implemented. '

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Procedure SA-1-100 also included step by step guidance for administrative

l processing of permits and impairments, and provided detailed instructions for hot

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work fire watches and compensatory measures fire watches.

c. Conclusions

I The inspector concluded that procedure SA-1-100 provided excellent guidance for

j the conduct of fire protection activities at the station. The inspector considered

having all the guidance in one procedure a strength, since plant staff personnel can

find the guidance for any activity affecting fire protection in the one procedure.

F5 Fire Protection Staff Training and Qualification ,

l F5.1 Fire Briaade Trainina Records

a. Insoection Scope

i The inspector reviewed the monthly Fire Brigade Status Reports for 1997, the

l monthly Fire Brigade Reports for 1997, attendance sheets from several 1997 fire

brigade training sessions, and reviewed six lesson plans for fire brigade training. In

addition, the inspector discussed the training and qualification program with the

Fire Brigade Training Coordinator.

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l b. Observations and Findinas

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! BGE had committed to the 1975 edition of National Fire Protection Association

(NFPA) Standard 27, which required monthly training for fire brigade members.

l BGE was conducting training for the fire brigade on a monthly basic. The monthly

topics were presented by the fire and safety technicians (FASTS). Attendance

records were entered into the computer tracking system for training. A printout

was generated monthly showing the training status of each person qualified as a

fire brigade member. The fire brigade training coordinator used that report to

generate a monthly fire brigade report, which was a matrix showing each person's

training status. Training which will expire during the month was shown in blue,

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and training which expired was shown in red. The monthly fire brigade report was

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used by the FASTS to check the designated fire brigade members at the beginning

of each shift to ensure that their qualifications were up to date.

Physical examinations were conducted annually by the medical department.

Physicals were currently conducted by physicians or physician's assistants from

l Johns Hopkins University. On several occasions during the past five years, BGE

l has had the physician or physician's assistant attend, and participate in, the annual

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fire school to give them a better perspective on what constitute the physical

requirements for fire fighters. Physical qualification status was automatically

down-loaded to the " Training Server" software which was used to generate the

monthly status report.

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The training plans the inspector reviewed are listed in Attachment 2. Each lesson

plan included discussion topics, lists of demonstration equipment needed for the

lesson, and a set of questions for the students.

c. Conclusions

Based on the review of the monthly fire brigade reports, the computer printouts of

individuals' training status, and review of several lesson plans, the inspector

concluded that the fire brigade qualification was appropriately tracked and

controlled. In addition, the inspector considered the color coding of expired, and

soon to expire, training on the monthly reports an excellent aid to the supervisors

- for identifying training needs, and for the FASTS to identify qualified fire brigade

members.

F7 Quality Assurance in Fire Protection Activities

F7.1 Quality Assurance Audits of Fire Protection Proaram

a. Insoection Scooe

The inspector reviewed audits of the fire protection program conducted since the

last inspection, to evaluate the depth of review, and whether identified deficiencies

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were being appropriately addressed. Specific audits reviewed were:

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Audit Report 96-13, Triennial Fire Protection, dated January 20,1996

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Report of Audit No. 95-4, Fourth Quarter 1995, dated December 19,1995

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Report of Audit No. 95-2, Second Quarter 1995, dated July 7,1995

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Report of Audit No. 95-1, First Quarter 1995, dated April 19,1995

b. Observations and Findinas

BGE had included fire protection in the routine audit program performed by Nuclear

Performance Assessment, rather than performing only a single audit each year.

l Experienced fire protection personnel from an outside entity were included in one

of the assessments performed each year. In addition, Nuclear Performance

Assessment performs a triennial review of the program, which includes an outside

auditor.

! The audits found the program to be generally well implemented, with only minor

l. findings. The triennial review performed in 1996 found an issue of some import.

The review of training and qualification found a computer programming problem

which affected updating the Calvert Cliffs Site Training Matrix for BGE offsite

employees. BGE formed a " Focus" group to identify the cause, and extent of the

problem and to work out a solution. The FPE stated that the problem did not

resurface during the 1997 outage.

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c. Conclusions

Based on the lack of repeat findings, and the issuance of issue Reports and

- Programmatic Deficiency Reports (PDRs) for significant findings, the inspector

concluded that the fire protection program audits were effective in identifying

problems and initiating corrective actions.

F8 Miscellaneous Fire Protection Activities

F8.1 ' BGE Self-Assessment of Comoliance with Anoendix R to 10 CFR 50

a. Insoection Scope

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The inspector reviewed the report of the BGE self-assessment of compliance with

Appendix R to 10 CFR 50, which was conducted during October and November

l 1996, and the Appendix R/HVAC Project Plan and Scoping Document, issued in

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August 1997. -In addition, the inspector reviewed issue Report (IR) 1-010-010,

dated September 6,1996,IR1-011-955, dated September 6,1996, and Priority 3

' Root Cause Analysis for PDR 96029, dated March 7,1997.

i b. Observations and Findinas

In response to escalated enforcement relating to switchgear room ventilation

issues in 1996, BGE performed a self-assessment of compliance with Appendix R

to 10 CFR 50. The assessment was conducted in October and November of

,

1996, and was led by Nuclear Performance Assessment personnel, with technical

l expertise augmentation by personnel from Engineering and Planning Management,

l Inc. (EPM). The assessment focused on Appendix R, safe shutdown, fire

protection regulatory framework, and key related programs. The team identified

34 specific issues for additional evaluation and correction, as appropriate.

Self-assessment team findings were broken down into three groups as follows:

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Group 1 Concerns - Corrective Actions Recommended

These concerns consisted of issues which were regarded by the team as

potentially not in compliance with regulatory guidance, and not currently

l_ active in BGE's corrective action program.

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Group ll Concerns - Actions to be Completed

These concerns consisted of issues which the team considered might be

not in compliance with regulatory guidance, but which were currently under

review or in the design process for correction. ,

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Group 111 Concerns - Recommendations for Improvements l

These concerns were areas considered by the team to be in compliance

with regulations, but where improvements to the fire protection and safe

shutdown programs were warranted.

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Pending further review of the specific issues, corrective actions already taken, and

evaluation under the criteria in NRC's Enforcement Policy (NUREG-1600), the

potential for a number of these issues to be not in compliance with NRC regulatory

{

requirements is unresolved (URI 50 318&318/97-080-08) I

c. Conclusions

!

l Based upon the results of the BGE self-assessment, and the project plan for

l addressing the issues raised, the inspector determined that the self-assessment

was a good initiative, and valuable tool for BGE to identify areas for improvement

, in their fire protection and post-fire safe shutdown programs. i

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F8.2 (Closed) Violation 50-317&318/97-05-04.Emeraency Liahtino Units

a. Insoection Scope i

The inspector reviewed NRC Integrated Inspection Report 50-317:318/97-05,and

its associated Notice of Violation (NOV), BGE's response to the NOV dated

l November 17,1997, discussed emergency lighting unit (ELU) history with the FPE

l and the system engineer, and observed the condition of ELUs during plant tours

and a walkdown of Unit 2 technical procedure AOP-9J, Rev. 3, " Safe Shutdown

Due to a Severe Fire in Room 311 Unit 2 Switchgear Room 27'."

b. Observations and Findinas

ELU maintenance was not well tracked in the past at CCNPP. In 1995,the system

l engineer initiated tracking and trending of the ELU corrective maintenance, to

identify high failure items. Recurring failures in batteries was found, especially in

high temperature and high vibration environments. Several ELU battery boxes in

l the turbine buildings have been relocated to reduce vibration effects, and the main

l steam isolation valve room battery boxes have been relocated to a lower

temperature area outside the room. BGE has begun replacing the lead-acid

! batteries with gel-cells, which should have a better life. All future battery

replacements will use gel-cells.

In addition, BGE has conducted " black-out" tests in most areas of the plant to

evaluate the positioning and effectiveness of the emergency lights. These tests

! confirmed the adequacy of the lights to provide sufficient illumination to perform

required post-fire safe shutdown tasks.

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l During the field walkdown of AOP-9J, the inspector observed the condition of the

emergency lights, and evaluated the aiming of the light heads. The inspector

found that the paths to all the safe shutdown equipment requiring local manual

operation were illuminated, and that the equipment was also illuminated. All the .

accessible lights on the routes were verified to be functioning by the FPE I

depressing the test switch, and the inspector observing the illuminated areas.

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By letter dated October 6,1997, BGE requested two specific exemptions to the

requirements of Section Ill.J of Appendix R to 10 CFR 50. These exemptions

relate to using the diesel generator backed security lights for exterior areas of the

plant, and the use of portable lights in high radiation areas and switchgear cabinet

interiors. At the time of the inspection, the request had not received final action

by NRC.

To improve the reliability of the ELUs, BGE has entered them into the maintenance

rule program. At the time of the inspection, the performance criteria and goals for

ELUs were under development. BGE intends to run the ELUs to failure.

Additional actions taken by BGE to ensure the ability of plant operators to perform

post-fire safe shutdown manual actions included the purchase of helmet-mounted

lamps with eight-hour battery packs. These lamps will supplement the installed

battery-bacl:ed ELUs and compensate for any failures which do occur. The battery

packs for the helmet-mounted lamps will be tested for eight hour discharge

capability each quarter.

c. Conclusions

Based on observations of the condition of the emtr,gency lighting units in the plant,

discussions with the FPE, discussions with the system engineer, review of

maintenance trending data, and review of the response to the notice of violation

50-317,50-318/97-05-04 regarding emergency lighting, the inspector determined

that the emergency lights were in good condition, and that BGE was taking actions

to improve the reliability of the ELUs and to compensate for any ELU failures which

may occur. This violation is closed.

P1 Conduct of EP Activities

The inspectors reviewed the documentation for a Notification of Unusual Event

(UE) that occurred on May 29,1997 to verify whether the response was in

accordance with NRC regulations and BGE's emetgency response plan (ERP). The

UE was declared for a small reactor coolant leak requiring the shutdown of the

plant. The event was properly classified in accordance with BGE's procedures.

BGE made all the required notifications, including that made to the NRC operations

center, within the required time periods. The inspectors concluded that BGE's

response to this event was made in accordance with NRC regulations and the ERP.

P2 Status of EP Facilities, Equipment, and Resources

a. Inspection Scope (82701)

The inspectors toured the emergency operations facility (EOF), the emergency

news center (ENC) and the farm demonstration building to ensure that these

facilities were being maintained in accordance with the approved ERP and

procedures. The inspectors also inspected a survey team vehicle to ensure that it

was adequately supplied. The inspectors discussed habitability issues for the

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technical support center (TSC) with the EP Director and the licensing engineering

staff; and, reviewed equipment inventory and communication circuit testing

surveillances to verify compliance with the ERP and NRC regulations.

a

b. Observations and Findinas

The EOF is a dedicated facility located just outside of the 10-mile emergency

planning zone. The inspectors observed that the facility had all of the required

equipment with only a few minor discrepancies. Two of the telephones used for

notification of offsite authorities were not operating properly. BGE investigated,

and corrected the problem.

The Emergency News Center (ENC) is not a dedicated facility. The equipment and

supplies used for its operation are kept in carts in a locked closet. There were only

minor discrepancies in the supplies listed on the checklists for the ENC. The

equipment checklists were posted on the carts, but these posted checklists were

not the current revision. BGE removed the outdated checklists. The inspectors did

not identify any deficiencies at the farm demonstration building, where responders

entering the site under adverse radiological conditions would be staged and

outfitted in protective clothing and respiratory protection.

The TSC is located above the control room and is part of the control room

ventilation envelope. Because of design inadequacies of the control room

ventilation system, which have already been documented in an NRC Letter dated

August 28,1997, BGE provides for self-contained breathing apparatus (SCBA)

usage by the control room staff in the event of a serious loss of coolant accident.

BGE also credits the use of potassium iodide (Kl) tablets for blocking the uptake of

radioactive iodine in the event of an iodine release following an accident.

There are adequate SCBAs for use by all control room personnel and all are

qualified and trained in the use of SCBAs. There are not adequate SCBAs for the

TSC responders who would be recalled following an accident. Nor are all TSC

responders qualified for SCBA use. BGE takes credit for Kl blocking of radioactive

iodine for the majority of TSC responders. BGE has not, however, determined if all

TSC responders are able to either wear a SCBA or ingest Kl tablets (i.e., they are

not allergic to iodine). Based on the inspectors' concerns, BGE has initiated a

survey to determine which TSC responders are unable to take either of the above

protective actions. BGE also initiated an issue report to document this problem

and initiate corrective action.

A survey team vehicle was inspected and had all of the supplies required. The

vehicle was operationally ready except for a dead battery. The inspectors

expressed concern over the ability of the teams to rapidly mobilize with a vehicle

in such a condition. BGE replaced the battery and the inspectors verified that the

vehicle was operational the next day. The inspectors reviewed the records for

facility inventories. All facility inventories except one are completed by a

technician in BGE's emergency planning unit (EPU). Inventories are completed

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quarterly and following equipment use. The inspectors noted no significant

discrepancies.

The EPU turned over responsibility for communication circuit testing to the

Telecommunications Department (TCD) it. September 1996. The TCD conducted I

tests of the circuits quarterly, despite the fact that NRC regulations require

monthly testing of communication links to the NRC and to the contiguous State

and local governments. The TCD had tested these circuits quarterly instead of

monthly from September 1996 through September 1997. BGE's audit 97-10, of

the emergency planning (EP) program, identified the failure to perform monthly

tests of the communication circuits used to communicate with the NRC. This

audit was performed in September 1997 and an issue report (IR) was written to

document this fact. BGE responded to the IR, performed corrective action and

closed it out.

The inspectors noted that the communication circuits used to communicate with

State cnd local governments had not been tested monthly during the same interval

(September 1996 through September 1997). Monthly tests were being conducted

from September 1997 through December 1997. Discussions with TCD : staff

revealed that BGE was unaware that these circuits required the same monthly

testing as the NRC communication links. These circuits were tested monthly

during October to December 1997 due to workups and/or troubleshooting for the

biennial exercise of November 1997. Further discussions with the EP Director

revealed that BGE's self assessment of the problems noted in an issue report were

ongoing, despite the closure of IR; i.e., the EPU was planning to investigate the

regulatory compliance of all communication circuit testing.

In a February 2,1998, meeting between BGE and NRC Region I management, the

EP Director presented BGE's actions taken for correction of the communications

circuit testing problems described above. These actions were: (1) the

reinstatement of monthly testing requirements for the circuits ia question, (2) the

resumption of tracking the communication surveillances by the EPU, and (3) the

addition of a step to the EPU task tracking schedule to evaluate changes to that

schedule for potential decreases of effectiveness of the emergency plan.

Additional details concerning this meeting are documented in report section X3.

c. Conclusions l

Overall, the inspectors concluded that the EP facilities, equipment, supplies and

instrumentation were being adequately maintained despite the deficiencies noted.

These facilities, equipment, and supplies would be able to perform their intended

functions in the event of a radiological accident. j

The inspectors considered BGE's failure to screen TSC responders for Kl sensitivity

to be an oversight worthy of corrective action. They noted that BGE was

aggressively pursuing this corrective action by the initiation of the IR and the

responder questionnaire. The inspectors are tracking this item as an inspector l

follow-up item to assess BGE's corrective actions to ensure protection of TSC i

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responders while the control room ventilation system is still degraded. (IFl 50-

317&318/97-08-04)

l The inspectors considered the facility inventories to be adequately performed. The

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inspectors concluded that the failure to do monthly communication circuit testing

with the NRC, and State and local governments, from September 1996 through

September 1997, was a violation of NRC requirements (VIO 50-317&318/97-08-

05). Despite the fact that BGE self-identified their failure to perform adequate

testing of circuits for communication with the NRC, the corrective actions taken by

BGE were not effective in identifying the failure to perform communication circuit

testing with State and local governments for four months after the initial

identification of the violation.

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The inspectors reviewed BGE's corrective actions which were taken prior to the

inspection exit interview and which were presented in the February 2,1998

meeting, and considered them to be adequate in response to the violation.

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P3 EP Procedures and Documentation

a. Insosction Scope (82701)

The inspectors reviewed recent changes BGE made to its ERP and the Emergency

Response Plan implementing Procedures (ERPIPs). The inspectors performed this

review in the NRC reDional office to verify that BGE's changes to these documents

were made in accordance with 550.54(q) of NRC regulations; i.e., that the

changes did not reduce the effectiveness of the approved ERP and the ERP, as

changed, continued to meet the requirements of $50.47(b) and Appendix E to

Part 50 of NRC regulations. A list of the specific ERP and ERPIP changes reviewed

i is included as Attachment 3 to this report. The inspectors reviewed the 50.54(q)

l evaluations performed for selected changes during the onsite inspection.

b. Observations and Findinos l

l Based upon BGE's determination that the changes did not decrease the overall

effectiveness of the ERP and after limited review of the changes, the inspectors

l determined that no NRC approval was required, in accordance with

l 10 CFR 50.54(q).

l BGE's 50.54(q) evaluations were adequately written to address the elements of

l emergency preparedness that would indicate potential decrease of effectiveness of

the emergency plan.

c. Conclusions

The inspectors concluded that BGE's changes to the ERP and ERPIPs listed in

Attachmant 3 and reviewed onsite were made in accordance with 650.54(q) of

NRC regulations.

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P4 Staff Knowledge and Performance in EP

a. Inspection Scooe (82701)

l

The inspectors conducted tabletop walkthroughs with two on-shift chemistry

technicians who perform interim radiological assessment until the activation of the

offsite dose assessment staff. Each technician was given two scenarios involving

hypothetical gaseous releases of radioactive material offsite. These scenarios

were conducted in the simulated control room under static conditions. The

technicians were evaluated to determine if they were able to gather information for

use in generation of accurate offsite dose consequence assessments.

b. Findinas and Observations

Both technicians demonstrated familiarity with the location and reading of the

radiation monitor displays in the simulated control room. They both knew where

the computer for the automated dose assessment model was located and knew

how to start up the automated dose assessment program. Both technicians

assumed an incorrect isotopic concentration for their first scenario. They assumed ,

an isotopic breakdown based on reactor coolant activity instead of gap activity, as j

would be required based on the radiation monitors' indications. This error yielded

non-conservatively low dose projections compared to the intended values for the

scenarios.

Step 1.E in the procedure the technicians were using, ERPlP 107 (Interim

Radiological Assassment), requires the technician to obtain concurrence of the

interim Site Emergency Coordinator (SEC) on the type of accident to select for the

dose projection. Neither technician performed this step properly.

This error in choosing the wrong isotopic assumptions in calculating the offsite

doses is similar to that noted '. iring the last full participation emergency

preparedness exercise, held on November 18,1997, (NRC Inspection Report

50-317&318/97-09). In that exercise, the NRC assessed the EOF staff's failure to j

use the proper isotopic mix as a causal factor in their inability to effectively use the '

computer-based dose assessment model to give reliable offsite dose projections.

The NRC classified this issue as an exercise weakness, requiring corrective action. ]

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c. . Conclusions  ;

The inspectors concluded the technicians were adequately trained in most of their i

duties as interim radiological assessment personnel. They were not adequately

trained to implement the procedure to obtain the concurrence of the SEC. Nor

were they trained adequately to qualitatively interpret the significance of the i

radiation monitor readings as far as the level of core damage they were indicating.

This training deficiency raised concern on the part of the inspectors as to the

effectiveness of BGE's training of the on-shift dose assessment staffs to be able to

provide consistently accurate dose projections. This deficiency is a violation of

NRC requirements (WO 50-317&318/97-08-06).

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P5 Staff Training and Qualification in EP ,

I

a. Insoection Scone (82701)

!

The inspectors interviewed EP and security training administrators to determine the

level of oversight of the training program for emergency responders. The

inspectors also reviewed the ERP, the EP. PIP describing EP training administration

(ERPIP 904), the Emergency Response Training Program Manual (ERTPM) and l

continuing training examinations for selected members of the emergency response

organization (ERO).

b. Observations and Findinas (

The EP training program is administered in accordance with the ERP, ERPIP 904 y

and the ERTPM. The EP Director and the EP training coordinator, who works in

the Technical Training Unit, coordinate closely to oversee the program of providing

training and tracking the qualifications of ERO members.

The responsibilities for conduct of EP training rest with several Groups, including

emergency planning, technical training unit staff, general orientation training staff,

operations training, the safety and fire protection unit, the security training and  ;

support unit, and the facilities management communications staff. The EP training -

coordinator is a central coordinating point for these groups and maintains many of

the EP training records in a central location. A certain amount of records, most

notably lesson plans and examinations for some continuing EP training are

maintained by the individual organizations. Additionally, training for the

responders at the ENC is not within the scope of the ERP, and the EP training

coordinator does not review or comment on its quality or effectiveness.

Through their discussions with the EP and security training coordinators, the

inspectors learned that certain groups evaluate their students' knowledge of EP  ;

within the context of the students' overall continuing training programs. For l

'

l example, a small percentage of the questions on the annual requalification

examinations for security guards cover EP concepts. These EP questions are not

separately analyzed to evaluate a guard's knowledge of his or her EP duties.

Therefore, it is possible for a guard to miss all the EP questions on an exam and

still pass. That guard's lack of EP knowledge would go undetected. The

'

inspectors learned that the same situation existed with the basic emergency

, response training that is given as part of general orientation refresher training. The

I

inspectors discussed this issue with the training staff and the EP Director. BGE

l Indicated plans to review, and modify if necessary, their method of examination to

evaluate if conditions like the ones described above could occur.

The inspectors also learned that there is only one generic lesson plan for all EP

training administered by the EP training coordinator. All students are trained to the

ERPIP they follow in performiag their emergency response duties, because the

essential tasks the students perform are all described in the procedures. Under

this arrangement, students are tested on their knowledge of procedures, but the

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l test questions are based on explicit procedural references and the procedures are

l provided when the tests are administered. In such a situation, the students are

l tested on their ability to look up answers to the questions in the procedures.

l . The inspectors interviewed the EPU clerk who is tasked with ERO roster

maintenance to determine the level of oversight of ERO member qualifications.

The inspectors learned that the ERO qualification records are maintained in an

l electronic data base that is sortable to identify impending or recent qualification

l lapses. The inspectors' review of the ERO roster did not reveal any serious

shortages of responders.

! c. Conclusions

l

The inspectors concluded that the EP training program meets the requirements of

the ERP, the ERPIPs and the ERTPM. The inspectors further concluded that the

qualifications of ERO members were being closely tracked. However, there was

week central oversight of EP training activities. The inspectors consider the fact

that EP continuing training is " hidden" in overall requalification training for some

groups to warrant increased attention by the EP Director to ensure that the EP

training is being properly administered to, and evaluated for, these groups. The

inspectors considered the method of training to the ERPIPs to be valid, assuming

the ERPIPs contain all the tasks that responders will perform. However, the

inspectors consider the method of testing this training, with ERPIPs provided to the

examinees, not to be a good indicator of the trainees' knowledge of concepts.

! P6 EP Organization and Administration

l a. Insoection Scope (82701)

The inspectors interviewed the Manager-Nuclear Site Support Services and the

! Vice President-Nuclear Energy to determine their involvement and knowledge of

the administration of the EP organization at the site. The inspectors also

l interviewed the EP Director to discuss recent changes to the EPU staff and

activities.

b. Observations and Findinas

The Manager-Nuclear Site Support Services and the Vice President-Nuclear Energy i

were knowledgeable of the activities of the EPU. They were aware of recent

'

l changes at the site in the area of EP. They were conscious of the position of their

organization relative to the industry in the area of staffing. They held regular

meetings with the EP Director.

The EPU was decreased by one position as of the beginning of calendar year

1998. An EP technician left the unit. The technician was utilized in a less-than-

full-time capacity while with the EPU, spending a significant amount of time on

loan for outage management tasks. The EP Director does not plan to fill this

vacancy, but rather intends to use his available staff, two of which spend

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! significant fractions of their tirne working for offsite state agencies. The EP

l Director plans to use these persons for a greater percentage of the time to handle

l the additional work, relying on the other nuclear utility with radiological emergency

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preparedness obligations to the State of Maryland to assume a greater share of the

work for the State. The EP Director stated that this re-alignment of tasks has been

agreed to by all parties concerned.

c. Conclusions

Senior site management was adequately involved in and informed about EPU

activities. The EP Director had evaluated the reduction in his staff and

compensated for it by realignment of resources. The inspectors concluded that no

! reduction of emergency response capability is likely to occur from the recent

changes in the EPU organization.

P7 Quality Assurance in EP Activities

'

a. Inspection Scope (82701)

The inspectors reviewed reports of the last two annual EP audits - (Audits 96-17

and 97-10) conducted by the Nuclear Performance Assessment Department

(NPAD) and interviewed the lead auditors for these reports. The inspectors also 3

'

reviewed the EPU's self-assessment program and discussed the self-assessment

effort with the EP Director,

b. Observations and Findinas

The two audit reports that the inspectors reviewed, as well as the two audit plans

used in their formulation, were very different in their level of detail. Audit report

97-10 was much more comprehensive than audit report 96-17, which was

completed the previous year. The auditors explained the recent adoption of a j

,

Master Assessment Plan (MAP) by the Nuclear Performance Assessment j

l Department (NPAD) as the reason for the change in methodology and level of l

detail. This program established a more uniform method of program audits, using i

standardized checklists to audit such attributes as organization and administration, I

l and self-assessments. Both audit reports met all the requirements of 650.54(t) of j

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NRC regulations, including the evaluation of licensee interface with offsite

agencies. Audit report 97-10 generated seven issue reports. The audit also

identified an example of licensee non-compliance with NRC regulations regarding

l

testing of communication circuits for NRC notification. The inspectors'

assessment of this finding was documented in report section P2.

The EPU was extensively involved in self-assessment during the past year. They

performed 127 formal self-assessments that resulted in fourteen issue reports.

One of these self-assessments was for the licensee-identified failure to test

communication circuits used to notify the NRC within the required frequency. This

self-assessment was still ongoing at the time of the NRC inspection, and had not

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yet identified the fact that the circuit used to notify state and local agencies was

similarly affected,

c. Conclusions

The inspectors concluded that the NPAD audits met all regulatory requirements.

They considered the 97-10 audit report, written after the implementation of the

Master Assessment Plan, to be a substantial improvement over the 96-17 audit

report in both methodology and scope. The inspectors concluded that BGE's self- I

assessment program, with 127 self-assessments initiated in calendar year 1997, *

was a good initiative.

P8 Miscelianeous EP issues

P8.1 (Closed): Unresolved Item 50-317&318/96-06-04 q

Inspectors conducting the last EP program inspection in 1996 opened this item

because BGE had self-identified a deviation from its UFSAR and had not taken

corrective action to resolve the deviation. The UFSAR described the emergency

radios onsite as having digital voice protection, but BGE had removed this feature

to improve reception quality. BGE revised its ERPIP for making changes to the EP

program to include a review of proposed changes against the UFSAR, but failed to

correct the identified deviation. This item was classified as an unresolved item.

The inspectors performing this inspection verified that BGE had removed the

reference to the digital voice protection from the UFSAR. The inspectors reviewed

BGE's evaluations of the change both to the EP program and the UFSAR as

required in 150.54(q) and $50.59 of NRC regulations.

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The inspectors also reviewed BGE's ERPIP 900, which governs BGE's preparation

and control of the ERP and ERPlPs. The inspectors noted that the step for

checking the change against the UFSAR had been removed from this procedure

but that the requirement to review the UFSAR had been retained by reference to

procedure EN-1-102, Safety Evaluation Screenings and Safety Evaluations, in

Step 5.3.E.1 of ERPlP 900.

4

Based on their review of the above items, the inspectors concludea that BGE had

failed to update the UFSAR in a timely fashion for a change affecting the UFSAR.

BGE had also completed all corrective actions to remedy the problem and prevent

i recurrence of the problem. This failure constitutes a violation of minor significance

and is being treated as a Non-Cited Violation, consistent with Section IV nf the

NRC Enforcement Policy (NCV 50-317&318/97-08-07).

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S1 Conduct of Security and Safeguards Activities

i a. Insoection Scope (81700)

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Determine whether the conduct of security and safeguards activities met BGE's

commitments in the NRC-approved physical security plan (Plan) and NRC

l regulatory requirements. Areas inspected included: access authorization program;

alarm stations; communications; protected area access control of personnel and

packages.

b. Observations and Findinas

Access Authorization Proaram. The inspectors reviewed implementation of the

Access Authorization (AA) program to verify implementation was in accordance  ;

l with applicable regulatory requirements and Plan commitments. The review i

'

included an evaluation of the effectiveness of the AA procedures, as implemented,

and an examination of AA records for 10 individuals. Records reviewed included

both persons who had been granted and had been denied access. The AA

program, as implemented, provided assurance that persons granted unescorted

access did not constitute an unreasonable risk to the health and safety of the

public. Additionally, the inspectors verified by reviewing access denial records and i

applicable procedures, that appropriate actions were taken when individuals were i

denied access or had their access terminated which included a formalized process

that allowed the individuals the right to appeal BGE's decision.

Alarm Stations. The inspectors observed operations of the Central Alarm Station

(CAS) and the Secondary Alarm Station (SAS) and verified that the alarm stations

were equipped with appropriate alarms, surveillance and communications

L capabilities. Interviews with the alarm station operators found them

knowledgeable of their duties and responsibilities. The inspectors also verified, l

through observations and interviews, that the alarm stations were continuously

l manned, independent and diverse so that no single act could remove the plants

capability for detecting a threat and calling for assistance, and the alarm stations

did not contain any operational activities that could interfere with the execution of

the detection, assessment and response furctions. l

Communications. The inspectors verified, by document reviews and discussions

with alarm station operators, that the alarm stations were capable of maintaining

continuous intercommunications, and communications with each nuclear security

officer (NSO) on duty, and were exercising communication methods with the local

law enforcement agencies as committed to in the Plan.

Protected Area (PA) Access Control of Personnel and Hand-Carried Packaaes. On

February 4 and 5,1998, the inspectors observed personnel and package search

activities at the personnel access portal. The inspectors determined, by

observations, that positive controls were in place to ensure only authorized

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l individuals were granted access to the PA and that all personnel anu sod carried

y items entering the PA were properly searched.

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[ c. Conclusions

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l BGE was conducting its security and safeguards activities in a manner that

protected public health and safety and that this portion of the program, as

' implemented, met BGE's commitments and NRC requirements.

82 Status of Security Facilities and Equipment

a. insoection Scone (81700)

1:

Areas inspected were: Testing, maintenance and compensatory measures; PA y

assessment aids; PA detection aids and personnel search equipment.  !

b. Observations and Findinas

Testina. Maintenance and Comnensatory Measures. The inspectors reviewed

testing and maintenance records for security-relatea equipment and found that

i documentation was on file to demonstrate that BGE was testing and maintaining

systems and equipment as committed to in the Plan. A priority status was being

assigned to each maintenance request and repairs were normally being completed

,

within the same day a maintenance request necessitating compensatory measures

l was generated. The inspectors reviewed security event logs and maintenance

l work requests generated over the past six months. These records indicated that

the need for establishing compensatory measures due to equipment failures was

minimal and when implemented, the compensatory measures did not reduce the

effectiveness of the security systems as they existed prior to the failure.

l Additionally, BGE is in the process of developing and implementing an automated

tracking system for security equipment maintenance requests.

Assessment Aids. On February 3,1998, the inspectors evaluated the

effectiveness of the assessment aids, by observing on closed circuit television

(CCTV), a NSO conducting a walkdown of the PA. The assessment aids had good

picture quality and excellent zone overlap. Additionally, to ensure the Plan

commitments are satisfied, BGE has procedures in place requiring the

l implementation of compensatory measures in the event the alarm station operator

is unable to properly assess the cause of an alarm.

PA Detection Aids. On February 3,1998, the inspectors observed testing of all )

the intrusion detection systems in the plant protected area and the independent i

spent fuel storage installation (ISFSI) and determined they were functional and

effective, and met the requirements of the Plan.

Personnel and Packsae Search Eauioment. The inspectors observed both the

routine use and the daily performance testing of BGE's personnel and package

search equipment. The inspectors determined, by observations and procedural

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l reviews, that the search equipment performed in accordance with licensee

! procedures and Plan commitments.

c. Conclusions

t

BGE's security facilities and equipment were determined to be well maintained and

reliable and were able to meet BGE's commitments and NRC requirements.

l S3 Security and Safeguards Procedures and Documentation

a. Insoection Scope (81700)

Areas inspected were implementing procedures and security event logs. l

b. Observations and Findinas

Security Proaram Procedures. The inspectors verified that the procedures were

consistent with the Plan commitments, and were properly implemented. The

verification was accomplished by reviewing selected implementing procedures

associated with PA access control of personnel, testing and maintenance of q

personnel search equipment and visitor processing.

Security Event Loos. The inspectors reviewed the Security Event Log for the

previous eight months. Based on this review, and discussion with security _

management, it was determined that BGE appropriately analyzed, tracked, resolved

and documented safeguards events that BGE determined did not require a report to

the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

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c. Conclusions

i Security and lateguards precedures and documentation were being properly

implemented. Eved ! ngs v sre being properly maintained and effectively used to

l analyze, track, cnd resolve safeguards events.

S4 Security and Safeguards Staff Knowledge and Performance

a. Inspection Scope (8170G)

Area inspected was security staff requisite knowledge,

b. Observations arlifindinas

Security Force Reauisite Knowledae. The inspectors observed a number of NSO's

in the performance of their routine duties. These observations included alarm

station operations, personnel and package searches, visitor processing and

requalification range instruction. Additionally, the inspectors interviewed NSOs

and based on the responses to the inspector's questioning, determined that the

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NSOs were knowledgeable of their responsibilities and duties, and could effectively

carry out their assignments.

c. Conclusions

The NSOs adequately demonstrated that they have the requisite knowledge

necessary to effectively implement the duties and responsibilities associated with

their position.

S5 Security and Safeguards Staff Training and Qualification (T&Q)

a. Iriggection Scoce (81700)

Areas inspected were security training and qualifications, and training records.

b. Observations and Findinas

Security Trainina and Qualifications. On February 4,1998, the inspectors

randomly selected and reviewed T&Q records of 14 NSOs. Physical and

requalification records were inspected for armed, unarmed, and supervisory

personnel. The results of the review indicated that the security force was being

trained in accordance with the approved T&Q plan. Additionally, the inspectors

observed requalification range instruction, performed by the training staff. The

training included a demonstration of the penetration capabilities of ammunition and

the significance of selecting proper cover in the event of a weapons engagement.

The instructors were knowledgeable of the course material and presented it in an

effective manner.

Trainina Records. The inspectors was able to verify, by reviewing training records,

that the records were properly maintained, accurate and reflected the current

qualifications of the NSOs.

c. Conclusigna

Security force personnel were being trained in accordance with the requirements of

the Plan. Training documentation was properly maintained and accurate and the

training provided by the training staff was effective.

S8 Security Crganization and Administration

a. Inspection Scoce (81700)

Areas inspected were management support, effectiveness and staffing levels.

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b. Observations and Findinas

Manacement Sucoort. The inspectors reviewed various program enhancements

made since the last program inspection, which was conducted in June 1997,

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These enhancements included the procurement of cellular phone capability in the

l security vehicles for enhanced communication capability and the security screening

database system was updated to improve efficiency and reduce the potential for

human error.

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l Manaaement Effectiveness. The inspectors reviewed the management

organizational structure and reporting chain. The Director-Nuclear Security's

position in the organizational structure provides a means for making senior

l management aware of programmatic needs. Senior management's positive

l response to requests for equipment, training and resources, in general, has

contributed to the effective administration of the security program.

Staffina Levels. The inspectors verified that the total number of trained NSOs )

immediately available on shift meets the requirements specified in the Plan. .

c. Conclusions. The level of management support was adequate to ensure effective

implementation of the security program, and was evidenced by adequate staffing

levels and the allocations of resources to support programmatic needs.

S7 Quality Assurance (QA) in Security and Safeguards Activities 5

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a. Insoection Scope (81700) l

Areas inspected were audits, problem analyses, corrective actions and

effectiveness of management controls,

b. Observations and Findinas

Audits. The inspectors reviewed the 1997 QA audit of the security program,

conducted August 18 through September 23,1997,(Audit No. 97-13) and the 1

1997 QA audit of the fitness-for-duty (FFD) program, conducted April 16 through  !

May 21,1997,(Audit No. 97-06). The audits were found to have been conducted

in accordance with the Plan and FFD rule. To enhance the effectiveness of the i

audits, both audit teams included an independent technical specialist.

The security audit report identified one finding and four recommendations. The {

finding was associated with security equipment not being listed on the currunt

Controlled Materials List. The FFD audit identified one finding and three

recommendations. The FFD finding was associated with employees exceeding  !

overtime limits and the potential for fatigue to impac1 an individual's fitness-for-  !

duty. The inspectors determined that the findings were not indicative of j

programmatic weaknesses, and the findings would enhance program effectiveness. j

l Inspector discussions with security management and FFD staff revealed that the l

l responses to the findings were completed, and the corrective actions were l

effective.

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Problem Analyses. The inspectors reviewed data derived from the security

department's self-assessment program. Potential weaknesses were being properly

identified, tracked, and trended.

Corrective Actions. The inspectors reviewed corrective actions implemented by

BGE in response to the QA audit and self-assessment programs. The corrective

actions were effective, evidence by a reduction in personnel performance issues

and loggable safeguards events.

Effectiveness of Manaaement Controls. The inspectors observod t' at BGE has

programs in place for identifying, analyzing and resolving problems. They include

the performance of annual QA audits, a departmental self-assessment program and

the use of industry data such as violations of regulatory requirements identified by {

I

the NRC at other facilities, as a trigger for performing a self assessment.

c. Conclusions

The review of BGE's Audit program indicated that the audits were comprehensive

in scope and depth, that the audit findings were reported to the appropriate level

of management, and that the program was being properly administered. In

addition, a review of the documentation applicable to the self-assessment program

indicated that the program was effectively implemented to identify and resolve l

potential weaknesses.

V. Manacement Meetinas

X1 Review of UFSAR Commitments

While performing the inspections discussed in this report, the inspectors reviewed

the applicable portions of the UFSAR that related to the areas inspected. Since the

UFSAR does not specifically include security program requirements, the inspectors

compared licenses activities to the NRC-approved physical security plan, which is

the applicable document. While performing the inspection discussed in this report,

the inspectors reviewed Section 5.5(D) of the Plan, titled " Visitor Access". The

inspectors determined, by interviews with Nuclear Security Officers (NSOs),

observations, and procedural reviews, that visitor access was being controlled and

maintained as required in the Plan.

The following inconsistency was noted between the UFSAR and the plant

practices, procedures and/or parameters observed by the inspectors. As described

in Report Section 01.2, UFSAR figure 7-12 also indicates that the setpoint for the

upper electrical limit or the " full out" position was at 136 inches. Additionally, the

Operating Instructions specify aligning the primary CEA position indicating system

to 135 inches when the CEAs are at the " full out" position. This figure was

discussed with BGE personnel who stated that the " full out" position was actually

located at between 135 and 135.75 inches. BGE personnel initiated an issue

report to investigate and resolve these apparent conflicts. BGE has an UFSAR

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Review Project in progress. Enforcement action regarding design issues identified

during the BGE review have been Unresolved (URI 50-317&318/96-10-03)pending

completion of the BGE initiative and NRC inspection of the completed review.

X2 Exit Meeting Summary

During this inspection, periodic meetings were held with station management to

discuss inspection observations and findings. On March 9,1998, an exit meeting

was held to summarize the conclusions of the inspection. BGE management in

attendance acknowledged the findings presented.

I

X3 Management Meeting Summary

On February 2,1998, BGE's Manager of Nuclear Site Support Services, the Site

Security Manager and the EP Director met with inspectors and the Chief of the

Emergency Preparedness and Safeguards Branch of the Division of Reactor Safety

at the NRC Region I office. This meeting was scheduled to introduce licensee

plant support area management to the Region i Branch CLf. At the end of the

meeting, the EP Director presented additional corrective actions taken in response

to NRC-identified violation 97-08-05 that deals with communication circuit testing.

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ATTACHMENT 1

PARTIAL LIST OF PERSONS CONTACTED

Bf1E

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C. Cruse, Vice President- Nuclear Energy Division

P. Katz, Plant General Manager

P. Spina, Acting Superintendent, Nuclear Maintenance

K. Neitmann, Superintendent, Nuclear Operations

T. Pritchett, Acting Manager, Nuclear Engineering ,

S. Sanders, General Supervisor, Radiation Safety I

T. Sydnor, General Supervisor, Plant Engineering I

J. Lemons, Manager Nuclear Support Services Department

A. Edwards, Director Nuclear Security

J. Holleman, Fitness-for-Duty Administrator

. J. Alvey, Supervisor Security Training and Support

! M. Burrell, Supervisor Security Screening, Training and Support

J. Frost, Nuclear Security Supervisor

D. Dean, Security Program Specialist

P. Hines, Security Training Specialist  ;

T. Roxey, Senior Engineer Nuclear Regulatory Matters

C. Sly Senior Engineer

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T. Forgette, Director- Emergency Planning

l J. Hardison, Emergency Response Training Coordinator

J. Osborne, Nuclear Regulatory Analyst

J. Phifer, Senior Assessor- Nuclear Performance Assessment Department

P. Pringle, Emergency Planning Analyst

! W. Ramstedt, Assessor- Nuclear Performance Assessment Department

l M. Tonacci, General Supervisor- Chemistry

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C. Sinopoli, Appendix R & Fire Protection Engineer

l J. Wood, Fire Protection Design Engineer

l L. Williams, Emergency Lighting System Engineer

l D. Buffington, Fire Protection System Engineer

L. Nuse, Fire Protection Specialist

l W. Hale, Senior Technical Instructor

G. Cooper, Sr. Electrical Engineer

E. Mc Cann, Electrical Engineer

N_!1C

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l A. Dromerick, Project Manager, NRR

T. Hoeg, Reactor Engineer

F. Laughlin, Resident inspector- Salem

G. Meyer, Chief, Civil, Mechanical, and Materials Engineering Branch, DRS

L. Nicholson, Deputy Director, Division of Reactor Safety

J. Wiggins, Director, Division of Reactor Safety

K. Kolaczyk, Operations Engineer

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Attachment 1 2

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INSPECTION PROCEDURES USED

IP 61726: Surveillance Observations

IP 62707: Maintenance Observation

IP 71707: Plant Operations

IP 82701: Operational Status of the Emergency Preparedness Program

i IP 92904: Followup - Plant Support

IP 81700: Physical Security Program for Power Reactors

l lP 64704: Fire Protection Program

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IP 64150: Triennial Postfire Safe Shutdown Capability Reverification

L ITEMS OPENED, CLOSED AND DISCUSSED

Opened

l

50-317,318/97-08-01 VIO Failure to establish adequate test procedures for the

secondary CEA position indicating system

50-317/97-08-02 VIO Failure to meet TS 3.1.3.3 when two CEA position

indications systems were inoperable

l 50-317,318/97-08-03 NCV inadequate design contrcl of variable power supply

voltage settings

50-317,318/97-08-04 IFl Follow up on licensee actions to identify and protect

TSC responders from thyroid exposure during

accidents

50-317,318/97-08-05 VIO Failure to test communicatica circuits in accordance

with Part 50, appendix E, par. IV.E.9

50-317,318/97-08-06 VIO Training deficiencies in on-shift dose assessment staff

use of automated dose assessment model

50-317,318/97-08-07 NCV Survey team radios not compliant with UFSAR (URI)

50-317,318/97-08-08 URI Potential for issues identified during Appendix R self

assessment to be not in compliance with regulatory

requirements.

Closed l

50-317,318/96-06-04 URI Survey team radios not compliant with UFSAR (NCV)

f 50-317,318/97-08-03 NCV inadequate design control of variable power supply

voltage settings

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' Attachment 1 3

50-317,318/97-08-07 NCV Survey team radios not compliant with UFSAR

Discussed

50-317,318/96-10-03 URI Old design issues identified during the BGE UFSAR

review

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LIST OF ACRONYMS USED

AA Access Authority

ASCOA Automatic Sprinkler Corporation of America

BGE Baltimore Gas and Electric

CAS Central Alarm System

CCNPP Calvert Cliffs Nuclear Power Plant

! CCTV Closed Circuit Television

i CDA Containment Dose Assessment

CEA Control Element Assembly

CFR Code of Federal Regulations

CR/TSC Control Room / Technical Support Center

l ELU Emergency Lighting Unit

EOF Emergency Operations Facility

l ENC Emergency News Center

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EPZ Emergency Planning Zone

ERO Emergency Response Organization

ERP Emergency Response Plan

ERPIP Emergency Response Plan implementing Procedure

ERTPM Emergency Response Training Program Manual

FAST Fire and Safety Technician

FFD Fitness For Duty

FPE Fire Protection Engineer

HX Heat Exchanger

IFl Inspector Follow-Up Item

IR issue Report

ISFSI Independent Spent Fuel Storage Installation

Kl Potassium lodide

LCO Limiting Condition for Operation

LPSI Lower Pressure Safety injection

l MAP Master Assessment Plan

l MTC Moderator Temperature Coefficient

l NCV Non-Cited Violation

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NEF Nuclear Energy Facility

NFPA National Fire Protection Association

NOV Notice of Violation

NPAD Nuclear Performance Assessment Department

NPO Nuclear Plant Operations

NRC United States Nuclear Regulatory Commission

NSO Nuclear Security Officer

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l OSC Operations Support Center

PA Protected Area

PDR Public Document Room

(. P&lD Piping and Instrumentation Drawing

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QA Quality Assessment

QS Quality Services

RTV Room Temperature Vulcanizing

SAS Secondary Alarm System

SCBA Self-Contained Breathing Apparatus

SEC Site Emergency Coordinator

SG Steam Generator

T&Q Training and Qualification

TCD Telecommunications Department

TSC Technical Support Center

TS Technical Specification

UE Unusual Event

UFSAR Updated Final Safety Analysis Report

URI Unresolved item

VIO Violation

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ATTACHMENT 2

Fire Barrier Penetration Seals inspected and Drawings Referenced

Penetration Seal 2-BARR-2B/407-SOOO1

Penetration Seal 2-BARR-2B/407-SOOO2

Penetration Seal 2-BARR-2B/407-SOOO3

Penetration Seal 2-BARR-2B/407-SOOO4

Penetration Seal 2-BARR-2B/407-SOOO5

Penetration Seal 2-BARR-28/407-SOOO6

Penetration Seal 2-BARR-28/407-TOO1

Penetration Seal 2-BARR-2B/407-TOO2

Penetration Seal 2-BARR-2B/407 TOO3

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Penetration Seal 2-BARR-2B/407-TOO4

Penetration Seal 2-BARR-2B/407-TOO5

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Penetration Seal 2-BARR-28/407-C010

Penetration Seal 2-BAF?:-2B/407-C011.

Penetration Seal 2-BARR-2B/407-C012

Penetration Seal 2-BARR-2B/407-C013

Penetration Seal 2-BARR-2B/407-C015

Penetration Seal 2-BARR-2B/407 C016

Penetration Seal 2-BARR-2B/407-C017

Drawing No. 62152 SHOO 24,Rev. 3, Barrier Segment Drawing for I'lant Elevation 45'-O"

Drawing No. 61-406-A, SEC.108.0, Sheet 1, Rev. 2, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.0, Sheet 2, Rev. O, Fire Barriers / Stops ,

Drawing No. 61-406-A, SEC.108.1, Sheet 1, Rev. 3, Fire Barriers / Stops f

Drawing No. 61-406-A, SEC.108.1, Sheet 2, Rev. 3, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.1, Sheet 3, Rev. 4, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.1, Sheet 4, Rev. 2, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.1, Sheet 5, Rev. 3, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.1, Sheet 6, Rev. 3, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.1, Sheet 7, Rev. 3, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.1, Sheet 8, Rev. 2, Fire Barriers / Stops

Drawing No. 81-406-A, SEC.108.1, Sheet 9, Rev. 2, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.1, Sheet 10, Rev. 2, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.3, Sheet 1, Rev. 4, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.3, Sheet 2, Rev. 2, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.3, Sheet 3, Rev.1, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.3, Sheet 4, Rev.1, Fire Barriers / Stops

Drawing No. 61-406-A, SEC.108.3, Sheet 5, Rev. 4, Fire Barriers / Stops

Emergency Lighting Drawings Reviewed

Drawing No. 63401 SHOO 28,Rev.13, Emergency Lighting & Communication Elevation

45'-O" Unit 2 Auxiliary Building

Drawing No. 63402 SHOO 27,Rev. 9, Emergency LightinD & Communication Elevation 27'-

0" Unit 2 Auxiliary Building

Drawing No. 61402 SHOO 36,Rev. 9, Emergency Lighting & Communication Elevation 45'-

0" Turbine Bldg. & Service Building Unit 1 & 2

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! Attachment 2 2

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Drawing No. 61402SH0034,Rev.13, Emergency Lighting & Communication Elevation

l 12'-O" Turbine Bldg., Service Bldg. & Intake Structure Unit 1 & 2

i Drawing No. 61402 SHOO 30,Rev.12, Emergency Lighting & Communication Elevation

27'-0" Unit 1 Auxiliary Building

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Drawing No. 61402SH0029,Rev.12, Emergency Lighting & Communication Elevation

45'-0" Unit 1 Auxiliary Building

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Fire Brigade Lesson Plans Reviewed

Emergency Operations for the SCOTT 4.5 Pressure-Pak

Fire Fighting Foam and Equipment

NFPA 704 Haz-Mat identification System

incident Command System i

Fire Fighting Strategies

Emergency Elevator Operations

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, ATTACHMENT 3  !

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l Emergency Response Plan and implementing Procedures Reviewed

DOCUMENT DOCUMENT TITLE REVISION

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NO.

ERPIP-OO5 Recovery Organization Notification 2

ERPIP-201 Technical Support Center Director 2/5

ERPIP-202 Plant General Manager 2/1

ERPIP-208 Plant Parameters Communications 1/1

! ERPIP-301 Operational Support Center 4

ERPIP-401 Nuclear Engineering Facility (NEF) 3

ERPIP-105 Control Room Communicator 3/2

ERPIP-108 Interim Radiation Protection O/1

ERPIP-209 Technical Support Center Communicator 3/2

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ERPIP-303 - Radiation Protection Director 1/3

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ERPIP-310 Maintenance Team Leaders 2

ERPlP-312 First Aid Team Leader 1/3

ERPIP-315 Plant Parameters Communications-OSC O/5

ERPIP-322 First Aid Team Members 1/1

ERPIP-832 Emergency Work Permits 2/1

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ERPIP-900 Preparation of Emergency Response Plan and 5 l

Implementation Procedures

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Emergency Response Plan 23

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ERPIP-OO5 Canceled 2

ERPIP-105 Control Room Communicator 3/3  ;

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ERPlP-209 TSC Communicator 3/3

ERPlP-509 EOF Communicator 3/3

ERP!P-750 Security 4/2

ERPIP-760 Plant Parameters Communications, Media Center 2/O

ERPIP-B.1 Equipment Checklist 19/3

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Attachment 3 2

DOCUMENT DOCUMENT TITLE REVISION

NO. / CHANGE

NO.

ERPIP-105 Control Room Communicator 3/4

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ERPIP-3.0 immediate Action 18/9

ERPIP-102 Superintendent-Nuclear Operations 2/1

ERPIP-107 Interim Radiological Assessment 2/1

ERPIP-201 Technical Support Center Director 2/6

ERPlP-203 Chemistry Director 2/O

ERPIP-301 Operational Support Center 4/1

ERPlP-311 Chemistry Team Leader 1/3

ERPIP-401 Nuclear Engineering Facility (NEF) Director 4/O

ERPIP-501 Site Emergency Coordinator 3/1

ERPlP-503 Emergency Operations Facility (EOF) Director 3/O

ERPIP-511 Radiological Assessment Director  %

ERPIP-840 Canceled 3/0

ERPIP-841' Canceled 2/O

ERPIP-842 Canceled 2/O

E-Plan Attachment 1-2 (MAP) 24 ]

E-Plan Facilities and Equipment Section (#5) 24

ERPIP-3.0 Immediate Action 18/9 j

ERPIP 801 CDA Using Containment Rad. Dose Rates  %

ERPIP 803 CDA Using Hydrogen  %

ERPIP 810 Main Steam System Radioactivity Release Est. 2/0

ERPIP 308 Onsite Monitoring Team Leader O/3  ;

ERPIP 309 Dosimetry Team Leader 2/1

ERPIP 319 Dosimetry Team Members  %

ERPIP 506 Offsite Monitoring Team Leader O/3

ERPIP 507 Offsite Monitoring Team O/7

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Attachment 3 3

DOCUMENT DOCUMENT TITLE REVISION

NO. / CHANGE

NO.

1

ERPIP 720 Technical Representatives 2/2

ERPIP 750 Security 4/3

ERPIP B.1 Equipment Checklist 19/4

ERPIP 201 Technical Support Center Director 3/O

ERPlP 319 Dosimetry Team Members  %

ERPIP 105 Control Room Communicator 3/5

ERPIP 209 TSC Communicator 3/4

ERPIP 509 EOF Communicator 3/4

ERPIP 900 Preparation of Emergency Response Plan and 6/O

Implementation Procedures

ERPIP 210 CR/TSC Monitor 3/O

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ERPIP 308 Onsite Monitoring Team Leader 1/0

ERPIP 316 Operational Support Center Monitor 3/0

ERPIP 403 NEF Monitor- 3/O

ERPIP 703 Nuclear Security Facility Monitor 1/0

ERPIP 750 Security 4/5

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