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Insp Repts 50-317/89-10 & 50-318/89-10 on 890508-12.No Violations Noted.Major Areas Inspected:Training & Qualifications,External Exposure Controls,Internal Exposure Controls & ALARA
	ML20245A618
Person / Time
Site:	Calvert Cliffs
Issue date:	06/06/1989
From:	Loesch R, Pasciak W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20245A595	List: ML20245A593; ML20245A604; ML20245A618;
References
	50-317-89-10, 50-318-89-10, NUDOCS 8906220090
	Download: ML20245A618 (6)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION 1-

Report Nos. 50-317 89-10

50-318 89-10

Doc'et

k Nos. 50-317

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50-318.

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License'Nos. DPR-53 Category. C

DPR-69

Licensee: Baltimore Gas and Electric Company

MD Rts 2 & 4, P.O. Box 1475

-Lusby, Maryland 20657

Facility Name: Calvert Cliffs Nuclear Power Plant, Units 1 and 2

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Inspection At: Lusby, Maryland

Inspection Conducted: May 8-12, 1989

Inspector: M, m /' - /o,/2 /f'1

R.'Loesch, Radiation Specialist date

Approved by: (A d cr ct/ u C- 6 I

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W. Pasciak, Chief, Facilities Radiation

Protection Section

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Inspection Summary: Inspection conducted on May 8-12, 1989 (Combined Inspection

Report Nos. 50-317/89-10,50-318/89-10).

Areas-Inspected: Routine, unannounced inspection of licensee radiological

controls during the Unit 2 outage. Areas inspected included: training and

qualifications, external exposure controls, internal exposure controls, and

ALARA.

Results: One violation was identified (failure to follow procedures; details

Sections 4.0 and 6.0),

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0o90 890608

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DETAILS

1.0 ' Individuals Contactea

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1.1 Licensee Personnel

L. Russell Manager, CCNPP Department

R. Denton Manager, QASD

N. Millis General Supervisor, Radiation Safety, QASD

J. Lippold General Supervisor, Technical Engineering Services

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G. Phair Assistant General Supervisor, Radiation controls &

Support, QASD

L. Smialek Senior Plant Health Physicist, QASD

J. Lenhart Supervisor, Radiation Controls, Operations, QASD

S. Hutson Supervisor,' Radiation Controls, ALARA, QASD

S. Sanders Supervisor, Material Processing, QASD

G. Bell Licensing Engineering, NESD

1.2 NRC Personnel

V. Pritchett Resident Inspector

Attended the exit meeting on May 12, 1989.

Other licensee personnel were also contacted during the course of this

inspection.

.2.0 Purpose of Inspection

The purpose of this routine, unannounced inspection was to review the ;

implementation of the licensee's Radiological Safety Program during the

Unit 2 iefueling outage. Areas reviewed included:

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training and qualifications,

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external exposure controls,

- internal expusure controls, and

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ALARA.

3.0 Training and Qualifications

The inspector reviewed the tn.1ning and qualifications of radiation workers

and selected radiological controls personnel. The review was with respect

to criteria contained in Technical Specifications, licensee procedures and

10 CFR 19.12, " Instruction to Workers."

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Findings

.Within the scope of this review, no violations were identified. However,

the following weakness was identified and discussed with the licensee.

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- The licensee had implemented a program designed to keep radiation

t protection technicians up to date as procedures are changed or revised.

Radiation Safety Procedure Change / Revision Records are

circulated to all group supervisors who, in turn, de(RSPCRRs)

signate individuals

required to read and sign the cover sheet by a specified date. .The

inspector determined that 10 of the 12 RSPCRRs reviewed had not been

completed ~in a timely fashion. Some were as much as 60 days past their

< designated due dates. This backlog is indicative of a lack of supervisory

attention.to detail. In addition, although a program for disseminating

changes to the field was in.effect, the program has not been-formally

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proceduralized to assure continued and consistent implementation. When

brought.to the. licensee's attention, they stated that the technicians

a would be brought up to date in their required readings and that the

program would be formally documented in a procedure.

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4.0 External Exposure Controls

.The inspector. reviewed the adequacy and effectiveness of selected aspects.

, of the External Exposure Control Program. The review was with respect to

criteria contained in applicable licensee procedures, Technical

Specifications, and regulatory requirements.

'The following matters were reviewed:

- use of appropriate Special Work Permits (SWPs) for controlling

radiological work,

- performance and documentation of radiological surveys to support ongoing

work

-postingandbarricadingofradiationandhighradiationareas,

- use of calibrated radiation survey instrumentation, and

- placenent and use of appropriate personnel dosimetry.

Evaluation of licensee performance in the area was based on:

- independent radiation surveys performed by the inspector during plant

l' tours,

- observation of ongoing work activities,

- review of selected SWPs and associated radiological surveys, and

- discussions with cognizant personnel.

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Findings

Within the scope of this review, the following apparent violation was

identified:

- Inspector review of completed SWPs indicated numerous examples where the

radiation safety technicians had not performed the surveys in accordance

withtherequirementsindicatedonthejobcontroldatarecordJJCOR).

These examples included JCDRs associated with the following SWP s:

89-829 89-2303, 89-2305, and 89-2309. Procedure RSP 1-101,

" Radiological Surveys", states, in section 3.7.3, that all radiological

surveys shall be reviewed by the Su

Operations (SRCO)in(or tohis ensure that they are complete, of Radiati

designee)pervisor

correct and conta pertinent data. A final review shall be conducted by

the General Supervisor, Radiation Safety (or his designee) prior to final i

filing. The fact that the JCDRs had been through one or more levels of

review and did not contain records of required surveys indicates a lack

of adequate supervisory review.

When brought to the licensee's attention, an internal audit of all unit

records was promptly initiated to determine the extent of the

deficiencies and appropriate corrective actions.

This failure to follow procedures is an apparent violation of Technical

Specification 6.11, " Radiation Protection Program" (50-317/89-10-01,

50-318/89-10-01).

5.0 Internal Exposure Controls

The inspector reviewed the adequacy and effectiveness of selected aspects

of the internal exposure control program. The review was with respect to

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criteria contained in applicable licensee procedures and regulatory

requirements.

The following matters were reviewed:

- review of airborne radioactivity surveys for establishing radiological

control s,

- use of engineering controls to control airborne radioactivity,

- control and issue of respiratory equipment, and

( - bioassay measurements.

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The evaluation of licensee performance in this area was based on:

- review of documentation,

- independent review and observations of ongoing work, and

- discussions with cognizant personnel.

Within the scope of this review, no violations were identified.

The licensee has an adequate internal dosimetry program. Review of airborne

survev documentation indicated that general airborne contamination levels

have been low. When a job situation warrants, effective containment devices

and/or portable ventilation equipment was utilized to maintain internal

exposures ALARA. Respiratory equipment is well maintained and controlled.

6.0 ALARA

The inspector reviewed the adequacy and effectiveness of selected aspects

of the ALARA Program. Particular emphasis was placed on review of ongoing

work. The review was with respect to criteria contained in applicable

licensee procedures and regulatory guidance.

Evaluation of licensee performance in the area was based on review of

ongoing work, discussions with cognizant personnel, and review of

documentation.

Findings

Within the scope of this review, the following additional example of an

apparent violation was identified:

- Requests for ALARA field services (portable ventilation, breathing air

systems, containment devices, etc.)

shielding,lly are initiated

originated via an

by ALARA personnel

"ALARA Field Services Work Sheet", norma

as part of the process of writing an SWP/ALARA review. The ALARA

Coordinator specifies on the Work Sheet the frequency with which ALARA

personnel are required to inspect the job site to verify the integrity

and/or continued effective operation of the installed ALARA devices to

reduce unnecessar ersonnel exposure. The inspections

documentedona"yp/AreaAcceptanceInspectionReport.performedareDuring

Job a rev

of outage related ALARA Field Services Work Sheets and associated

Job / Area Acceptance Inspection Reports, the inspector noted numerous

examples where the ALARA personnel had not performed the inspections in

accordance with the prescribed inspection frequency as specified in

Procedure RSP 1-202, "ALARA Field Services", Section 6.3. Specifically,

these included jobs covered by SWPs 89-2038, 89-2501, and 89-2503. This

is an example of inadequate supervisory oversight (see Sections 3.0 and

4.0 of this report).

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This failure to follow procedures is an additional example of an apparent

violation of Technical Specifit:ation 6.11, " Radiation Safety Program"

(50-317/89-10-01,50-318/89-10-01).

Within the scope of this inspection, the following observations were made

and discussed with licensee personnel.

- Several jobs had exceeded their ALARA exposure estimates by a significant

margin. SWP 89-829, " Replace 118 RCP Seal", was 117% over its estimate

and the job had yet to be completed at the time of the inspection. Fest

job ALARA reviews typically are not performed until after the outage,

therefore no formal documentation was available to justify these

discrepancies. The inspector stated that either the initial estimates

were inaccurate or unforeseen circumstances (job scope, work environment)

had developed. The licensee stated that the post-job ALARA reviews would

capture the root cause and allow for improvements in maintained exposures >

ALARA. This will be reviewed during in a future inspection. l

- An aggressive exposure goal has been established for Unit 2 for 1989 of

335 person-rem, of which 235 person-rem is allocated for the outage. The

current outage exposure as of May 8, 1989, was 99 person-rem.

7.0 Exit Meeting

The inspector met with licensee representatives (denoted in Section 1.0 of

this report) at the conclusion of the inspection on May 12, 1989. The

inspector summarized the purpose, scope and findings of the inspection.

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ML20245A618

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