ML20245A618
| 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: |
| References | |
| 50-317-89-10, 50-318-89-10, NUDOCS 8906220090 | |
| Download: ML20245A618 (6) | |
See also: IR 05000317/1989010
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U.S. NUCLEAR REGULATORY COMMISSION
REGION 1-
Report Nos.
50-317 89-10
50-318 89-10
Doc'et Nos.
50-317
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50-318.
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License'Nos.
Category.
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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:
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R.'Loesch, Radiation Specialist
date
Approved by:
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W. Pasciak, Chief, Facilities Radiation
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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
Results: One violation was identified (failure to follow procedures; details
Sections 4.0 and 6.0),
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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
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- N. Millis
General Supervisor, Radiation Safety, QASD
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- 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:
training and qualifications,
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external exposure controls,
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internal expusure controls, and
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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
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protection technicians up to date as procedures are changed or revised.
circulated to all group supervisors who, in turn, de(RSPCRRs) individuals
Radiation Safety Procedure Change / Revision Records
are
signate
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
proceduralized to assure continued and consistent implementation. When
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brought.to the. licensee's attention, they stated that the technicians
would be brought up to date in their required readings and that the
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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.
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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
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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
Operations (SRCO)in(or his designee)pervisor of Radiati
surveys shall be reviewed by the Su to ensure that they are complete,
correct and conta
pertinent data. A final review shall be conducted by
the General Supervisor, Radiation Safety (or his designee) prior to final
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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
criteria contained in applicable licensee procedures and regulatory
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requirements.
The following matters were reviewed:
- review of airborne radioactivity surveys for establishing radiological
control s,
- use of engineering controls to control airborne radioactivity,
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- 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
etc.) are initiated via an
systems, containment devices, shielding,lly originated 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
documentedona"yp/AreaAcceptanceInspectionReport.performedareDuring a rev
reduce unnecessar
ersonnel exposure. The inspections
Job
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
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ALARA. This will be reviewed during in a future inspection.
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- 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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