IR 05000317/1997006: Difference between revisions

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{{Adams
{{Adams
| number = ML20203F436
| number = ML20248M087
| issue date = 12/05/1997
| issue date = 06/09/1998
| title = Insp Repts 50-317/97-06 & 50-318/97-06 on 970914-1101. Violations Noted.Major Areas Inspected:Integrated Insp Rept Includes Aspects of Util Operations,Maint,Engineering & Plant Support
| title = Ack Receipt of 980105 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/97-06 & 50-318/97-06
| author name =  
| author name = Doerflein L
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name =  
| addressee name = Cruse C
| addressee affiliation =  
| addressee affiliation = BALTIMORE GAS & ELECTRIC CO.
| docket = 05000317, 05000318
| docket = 05000317, 05000318
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-317-97-06, 50-317-97-6, 50-318-97-06, 50-318-97-6, NUDOCS 9712170379
| document report number = 50-317-97-06, 50-317-97-6, 50-318-97-06, 50-318-97-6, NUDOCS 9806120367
| package number = ML20203F390
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 38
}}
}}


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o-U.S. NUCLEAR REGULATORY COMMISSION REGION 1 License No DPR 53/DPR 69 Report No /97-06:50-318/97 06 Licensee: Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203 Facility: Calvert Cliffs Nuclear Power Plant Units 1 and 2 Location: Lusby, Maryland Dates: September 14,1997 through November 1,1997 Inspectors: J. Scott Stewart, Senior Resident inspector Fred L. Bower Ill, Resident inspector Henry K. Lathrop, Resident inspector James Noggle, Senior Radiation Specialist, DRS Paul H. Bissett, Senior Operations Engineer, DRS Laurie A. Peluso, Radiation Physicist, DRS Approved by: Lawrence T. Doerflein, Chief Projects Branch 1 Division of Fieactor Projects
June 9, 1998 Mr. Charles Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway
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Lusby, MD 20657- 4702        '
9712170379 971205 PDR ADOCK 05000317 G  PDR 2
SUBJECT:   NRC INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 AND NOTICE OF VIOLATION
 
==Dear Mr. Cruse:==
This letter refers to your January 5,1998, correspondence in response to our    l December 5,1997, letter.       l Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.
 
We appreciate your cooperation.
 
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Sincerely, Original Signed by:
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William A. Cook for Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects Docket Nos. 50-317 50-318 cc:
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T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)
EXECUTIVE SUMMARY Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection Report Nos. 50 317/97-06and 50 318/97-06 This integrated inspection report includes aspects of BGE operations, maintenance, engineering, and plant support. The report covers a seven week period of resident inspection and includes the results of announced inspections by radiation safety and operator licensing personne Plant Operations BGE actions to minimize risk during a reactor coolant pump seal replacement were notabl During the seal replacement, a number of control room deficiencies were corrected. The plant was recovered and returned to full power without complicatio The inspectors observed the BGE response to an automatic trip of Unit 1. Operator actions were very good and included completion of the appropriate emergency operating procedures, periodic status briefings, and detailed evaluation of plant conditions. BGE did a thorough review of the transient and after the cause of the trip was understood and corrected, a plant startup was authorized by management. The plant was restarted and returned to full power without complicatio The conduct of operations was professional and safety-conscious. The operations and engineering departments implemented multiple and detailed safety risk assessments for planned safety related equipment outages. The applicable system Technical Specification (TS) limiting conditions for operation (LCO) were entered and exited correctly for the equipment outage time The inspectors found that while BGE had not met their established goals for the number of control room deficiencies; efforts to reduce the total number of deficiencies had been
R. McLean, Administrator, Nuclear Evaluations    f J. Walter, Engineering Division, Public Service Commission of Maryland
; aggressive. No existing deficiency represented an immediate safety concer The inspectorr determined _that operator preparedness for use of self-contained breathing apparatus was weak. A number of operators did not know the location of the j equipment, some operators wors f acial hair that would inhibit SCBA use, and some
; operators had not trained with the equipment for five years. BGE responded to
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inspector concerns by requiring that operators be clean shaven and establishing a practical training plan for SCBAs.
cc w/ copy of Licensee's Response Letter:
K. Burger, Esquire, Maryland People's Counsel    !
R. Ochs, Maryland Safe Energy Coalition State of Maryland (2)
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9006120367 990609 l  PDR  ADOCK 05000317
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0FFICIAL RECORD COPY IE:01 u--_________. - - _ - - - - - - - . - - _ - - _ - - - _ - - -  _ -- --  __ -- _-- a


! The inspectors reviewed the licensed operator requalification program and found it was I
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implemented acceptably. Operator performance during the annual operating test was i good. The operations and training departments worked effectively to maintain operator knowledge and skills at desired levels of performance. Licensed operator exams were
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Charles Distribution w/ copy of Licensee's Response Letter:
administered appropriately; however, the inspectors noted some concerns in the areas of l simulator and JPM debriefs, JPM critical task identification, and evaluator cuin ii
B. McCabe, RI EDO Coordinator F. Bower - Calvert Cliffs S. Bajwa, NRR A. Dromerick, NRR L. Doerflein , DRP S. Adams,DRP R. Junod, DRP M. Campion, RI Nuclear Safety Information Center (NSIC)
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PUBLIC Region 1 Docket Room (with concurrences)
Inspection Program Branch, NRR (IPAS)
DOCDESK l


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o Executive Summary (cont'dl Maintenu 3 In general, maintenance was conducted safely and in accordance with approved procedures. The inspectors observed during maintenance inspections, that workers were knowledgeable and performed work effectivel A leak repair activity on the high pressure main turbine was initiated without normal engineering assessment. The effort was stopped by the BGE nuclear assessment department af ter identification that fire protection, injection pressure, and injection volume had not been assessed. The NRC inspectors considered the efforts of the BGE nuclear assessment department to be aggressive and prudent, initial mainwnance department preparations for the higt. pressure turbine leak repair were poo En9!DMilD2 in 1980, BGE increased the toxic material hazard from the on sita storage of liquid ammonia from 55 gallon drums to a 5600 gallon storage tank without completing a written safety evaluation. Further, BGE had approved the replacement of the 5600 gallon tank with an 8500 gallon tank without a written safety evaluation providing the basis that the change did not involve an unreviewed safety question. Safety evaluation screening reports completed for the tank installations, had not considered UFSAR Section 1.8, or UFSAR Figure 1- The inspectors found that BGE had stored ammonium hy6 oxide solution within the protected area boundary without ensuring that the plant was fully prepared for a potential spill of the storage tank contents. The need to place control room ventilation in the recirculation mode or have the licensed operators don respiratory protection had not been fully considered and procedures for response to an ammonia spill had not been develope The inspectors concluded that BGE was takin0 appropriate actions to address industry identified concerns 'with the f atigue of welds on the 18,2A, and 2B emergency diesel generator lube-oil and jacket water piping systems,  o On infrequent occasions, aircraf t have been observed flying at low altitudes over the Calvert Cliffs site, BGE had assessed airplane flyovers and concluded that flights over the plant did not represent a significant safety hazar Plant Supp_qrt The programs for radiologicel environmental monitoring (REMP) and meteorological monitoring (MMP) continued to be effective. Management oversight of the REMP and MMP was effective. The quality assurance audits were of sufficient technical depth to identify and assess program strengths and weaknesses. BGE audits evaluated the technical adequacy of implomenting procedures, technical specification and of fsite dose calculation manualimplementation, and practices, ill l
' DOCUMENT NAME: A:\RL970606.CC To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure  "E" =
Copy with attachment / enclosure "N" = No copy OFFICE Rl/DRP Rl/DRP NAME SAdams 54 LDoerflein p@ g 03/tt/98 .1937,/98 ,
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DATE r OFFICIAL RECORD COPY
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CIIARLES II. CRUSE  Daltimore Gas and Electric Company Vice President    C$tivert Cliffs Nuclear Power Plant Nuclear Energy    1650 Calvert Cliffs Parkway Lusby. Maryland 20657 410 495-4455
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January 5,1998 U. S. Nuclear Regulatory Commission Washington,DC 20555 ATTENTION:  Document Control Desk SUBJECT:  Calvert C:iffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 NRC Region I Integrated Inspection Report Nos. 50-317/97-06 and 50-318/97-06 and Notice of Violation REFERENCE:  (a) Letter from Mr. L. T. Doerflein (NRC) to Mr. C. (BGE), dated December 5,1997, NRC Region 1 Integrated Inspection Report Nos. 50-317/97-06 and 50-318/97-06 and Notice of Violation This letter provides Baltimore Gas and Electric Company's response to Reference (a), which identified six violations. Each of the violations cited has been individually addressed as specified in the Enclosure to Reference (a). Individual responses to each of these violations are provided in Attachments (1) through (6).
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. Document Control Desk j    January 5,1998 l    Page 2 J
f Should you have questions regarding this matter, we will be pleased to discuss them with you.      I Very truly yours,
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g,  /9L STATE OF MARYLAND  :
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COUNTY OF CALVERT  :
I, Charles II. Crtae, being duly swom, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this response on behalf of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.
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I S bsc bed defand ) sworn.thisbefore  d day  me aof  Notary (Public in and for the State of Maryland and County of u ls h v .1998.


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It Executive Summsry (cont'd)
WITNESS my Hand and Notarial Seal:        b/h1 AlJ b ltLL Notary Public  j My Cemmission Expires:        AA 9 Date i CliC/CDS/bjd Attachments cc: R. S. Fleishman, Esqui,e        Resident Inspector, NRC  l J. E. Silberg, Esquire        R. I. McLean, DNR Director, Project Directorate I-1, NRC      J.11. Walter, PSC A. W. Dromerick, NRC        L. T. Doerflein, NRC 11. J. Miller, NRC
The inspectors found that BGE had not developed and implemented a procedure to prevent personnel contaminations from occurring as a result of contaminated Anti-C clothing. Although no significant skin contaminations had been observed, Anti C articles that had been returned to Calvert Cliffs from the laundry vendor, were at times contaminated above the limits specified in tne Calvert Cliffs procedure for laundering of Anti C clothing. However no proceduro existed ' J.ich specified actions to be taken when articles were found above the monitoring limits, including criteria for sample expansion, assessment of the contamination in excess of the limits, and actions to ensure that laundered clothing contaminated above acceptable limits was not made available for general us Communication deficiencies were observed in a radiation safety technician turnover and in prejob briefing for a reactor coolant pump seal replacemen Radiation safety technician performance weaknesses were observed during high radiation area coverage of a reactor )lant pump seal replacement that included:
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poor placement of an air sampler, lace of knowledge of radiation levels of a canister ,
that was located in the work area, and inadequate control of a worker who was not wearing the required water resistant protective clothing and was observed spraying down a highly contaminated seal cartridg Good control and oversight to prevent foreign material from entering the reactor coolant system during reactor coolant pump seal replacement was observe During the initial containment entry following a reactor trip, two radiation safety technicians were observed by the NRC inspector making a high radiation entry without following the Special Work Permit requirement to wear the TLD on the outside of the Anti-C clothing, with the beta window expose The inspectots conducted walkdowns of various fire protection equipment, including fire hydrants, sprinkler piping, hose and nozzle storage boxes, and emergency fire pumps. All of the equipment was in good materiai condition and no problems were identified, iv


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ATTACHMENT (1)
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NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-01 A. 10 CFR 50.59 allows the holder of a license to make changes to thefacility as described in the safety analysis report, wl:houtprior commission approval, unless the proposed change involves an unreviewed safety question. 10 CFR 50.59(b)(1) requires that the licensee maintain records of changes and that these records include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
!o TABLE OF CONTENTS EXECUTIVE SUM M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Il TA BLE O F CO NT ENT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
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Report D e t a il s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. O pe r a ti on s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . *
01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 :
01.1 General Comments (71707) ...................... 1
- 01.2 Unit 1 Re actor Trip . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 02 Operational Status of Facilities and Equipment .............. 3 02.1 Engineerod Safety Feature System Walkdowns  . . . . . . . . . 3 7 02.2 Control Hoom Deficiencies . . . . . . , . . . , , . . . . . . . . . 3  !
02.3 Use of Self Contained Breathing Apparatus . , . . . . . . . . . 4 05 Operator Training and Qualification . . . . . . . . . . . . . . . . . . . . . . 5 05.1 General Sc ope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 05.2 Ex am Cont e nt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 05.3 Exam Administration and Evaluation . . . . . . . . . . . . . . . . . 6 05.4 Continuing Training ............................ 8
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05.5 Remedial Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 05.6 License Reactivation .................-........9
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08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . 9
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08.1 (Closed) Unresolved item 50 317&318/95 10-01 ....... 9 08.2 (Closed) Unresolved item 50 317&318/95 10 02....... 10 11. M a i n i e n a nc e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
< M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10


M1.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 M1.2 - Routine Surveillance Observations . . . . . . . . . . . . . . . . . 11 Ill . Engine e ring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . 12 El Conduct of Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 E1.1 Onsite Storage of Ammonia and other Toxic Chemicals . . 12 E2 Engineering Support of Facilities and Equipment ............ 15 E Emergency Diesel Generator Piping Operability . . . . . . . . 15 E 8 .- Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . 16 E8.1 Aircraf t Flight Hazards . . . . . . . . . . . . . . . . . . . . . . . . . 16 IV - Pl a nt Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17  !
10 CFR 50.71(e) requires that licensees periodically update the final safety analysis report to assure that the report contains the latest materialdeveloped.
R1 Radiological Protection and Chemiury (RP&C) Controls . . , . . . . 17 RI .1 The Radiological Environmental Monitoring Program . . . . . 17 H1.2 Meteorological Monitoring Program . . . . . . . . . . . . . . . . 19  !
R1.3 Secondary Chemistry Controliniplementat;on Chang . . . 20
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Contrary to the above, as of Oct'ober 15,1997, the screeningfor the installation of a 5600 gallon ammonium hydroxide storage tank, installed in 1986 and reviewed by Baltimore Gas and Electric Company (BGE) in 1996, failed to include a written safety evaluation which provided the determination that the change did not involve an unreviewed safety question. The hazardous material dbnsequence ofa spill ofammonia as described in the December 30,1980, BGE letter to the NRC, referencedin the UpdatedFinalSafety Analysis Report Section 1.8, Subsection Ill.D.3.4, and Updated Final Safety Analysis Report (UFSAR) Figure 1-2 were revised by the installation of the tank. As a result of not completing a safety evaluation, BGE alsofailed to update thefinal    j safety analysis report.


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Table of Contents (cont'd)
!  R2 Status of RP&C Facilities and Equipment . . . . . . . . . . . . . . . . . . 21
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  ' R3 RP&C Procedures and Documentation . . . . . . . . . . . . . . . . . . . 22 -
L ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Baltimore Gas and Electric Company accepts the violation.- We agrec that Figure 1-2 of the_UFSAR should have been PM Treatment ofinfonnation incorporated by re.ference in the UFSAR is's current industry ,    M
R3.1 Laundering of Contaminated Clothing . . . . . . . . . . . . . . . 22
  - topic.' We plan to implement necently issued Nuclear!EidrgylnstitseIguidando an'thfiibpic in aoocirdance   t E Wjk wiethe ubidule desribed be$ ' M MAMi~ 4IFW*lV Z* ~ W      W ' ' ?- # *4 11. REASONS FOR THE VIOLATION In 1997, a modification was issued to replace the 5600 gallon ammonia tank with an 8500 gallon ammonia tank and increase the ammonia concentration. This modification addressed all technical issues (e g., chemical spills, Control Room habitability), but responsible personnel failed to notice that the tank was indicated on the site plot plan. Therefore, the need to perform a 50.59 analysis was not identified.
;  R4 Staff Knowledge and Performance in RP&C . . . . . . . . . . . . . . . . 24-i R6 RP&C Organization and Administration . . . . . . . . . . . . . . . . . . . 26
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R6.1 Organization Changes and Responsibilities . . . . . . . . . . . 26-  i i   R7 Quality Assurance in RP&C Activities . . . . . . . . . . . . . . . . . . . . 27 .
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R7.1 Quality Assurance Audit Program ' . . . . . . . . . . . . . . . . . 27 - i R7.2 Quality Assurance of Analytical Measurements . . . . . . . . . 27
;  S8- Miscellaneous Security and Safeguards Activities . . . . . . . . . . . 28 F8 Miscellaneous Fire Protection issues . . . . . . . . . . . ... . . . . . . . . 28 3
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}  V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 9 7
. X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 9 i
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;    ATTACHMENTS
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i Attachment 1: Partial List of Persons Contacted Inspection Procedures Used items Opened,. Closed and Discussed List of Acronyms Used    !
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In addition, the fact that the tank was incorrectly identified as a morpholine tank was also not noticed and corrected.
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l. in 1991, we incorporated information summarizing certain Nuclear Regulatory Commission-issued Safety Evaluation Reports such as those relating to NUREG-0737. Rese summaries included references    i to the specific correspondence. Section 1.8, Subsection III.D.3.4 and its reference to BGE's 1980 letter
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l~ noted in this violation, was one case of this added material. %ese references were intended to guide future reviewers to relevant documents. It was 'not our intent that all information contained in these documents was to be considered " described in the Safety Analysis Report" when screening the subjects for 10 CFR 50.59 applicability.
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Summarv of Plant Status The inspection period began with Unit 1 shutdown to support replacement of a reactor coolant pump seal. The reactor returned to full power on September 22, 1997. Unit 1 tripped from full power on October 24 due to a loss of condenser vacuum (section 01.2) and was returned to full power on October 26,199 Unit 2 remained at full power during the inspection perio l. Onorations 01 Conduct of Operations -


01.1 Gentf el Comments (71707)
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Overall plant operations were conducted safely with a proper focus on continued nuclear safety. At the beginning of the inspection period, Unit 1 was shutdown in Mode 5 to replace the 118 reactor coolant pump seal. The  '
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replacement required that the reactor coolant system (RCS) be placed in the hQher risk, reduced inventory condition. In preparation, the operations department conducted briefings and established a reduced inventory plan that specified tra ning requirements, actions to minimize time in the reduced inventory condition, compensatory actions to ensure inventory control, and contingency actions should there be a loss of RCS inventory. Operators and other key personnel were trained on the plan and briefings for critical work in the containment included discussions of containrnent evacuation procedure ,
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The focus of training was personnel and nuclear safety during the higher riek condition. The inspectors reviraved the BGE plan and observed its implementation, BGE actions to minimize the risk of the reduced inventory condition were very good and the seal was replaced without problems. During the seal replacement outage, a number of control room deficiencies were worked and cleared. The plant was recovered and returned to full power on September 22,1997, without complicatio The inspectors reviewed the June 1997 World Association of Nuclear Operators (WANO) evaluation of Calvert Cliffs. The report was based on a two week team review of Calvert Cliffs activities in operations, maintenance, radiation protection, t.nd other areas. The report discussed a number of strengths and areas for iraprovement. No significant operability issues were identified and the inspectors were generally aware of issues ra!3ed in the evaluatio Using inspection Procedure 71707," Plant Operatior.3," the inspectors conducted frequent reviews of ongoing plant operations. In general, the conduct of operations was professional and safety conscious. The operations, maintenance, and engineering departments implemented roultiple detailed on-line safety risk assessments for planned safety related equipment cutages that
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ATTACIIMENT (1)
NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-01 III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED A detailed safety evaluation has been performed to ensure that the ammonia tank does not represent an Unreviewed Safety Question, and pending changes to UFSAR Figure 1-2 have been issued. -
IV. CORRECTIVE STEPS THAT WII I, BE TAKEN TO AVOID  FURTHER VIOLATIONS Over the past several years, extensive emphasis has been placed on ensuring changes to our facility are conservatively reviewed for 10 CFR 50.59 applicability. In order to ensure that design engineers are aware of the detail contained in the UFSAR Site Plan, training will be conducted concerning the details of this issue. In addition, we will conduct training of 50.59 reviewers to enhance awareness of those topics contained in Section 1.8 of the UFSAR.
Industry guidance has recently been issued by the Nuclear Energy Institute regarding 10 CFR 50.59. He Nuclear Energy Institute guidance directly addresses treatment of information incorporated by reference in the UFSAR. We plan to implement this domment by June 30,1998. In addition, a detailed review of the Calvert Cliffs UFSAR is currently in propess to identify and correct any inaccuracies. This review includes evaluating incorporation ofinformation from past NRC Safety Evaluation Reports. This review is expected to be completed by October 1998. He majority of UFSAR corrections that result from this review should be incorporated into the 1998 and 1999 revisions to the UFSAR. Rese steps will clarify our expectations for application of 10 CFR 50.59.
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V. DATE'WWFN FULL COMPLIANCE WTI.T. BE ACHIEVED.


included safety risk and trip risk assessments. Maintenance was sequenced to minimize the risk factors. The applicable system Technical Specification (TS)
We were in full compliance when the detailed safety evaluation was completed for the ammonia tank.
limiting conditione for operation (LCO) were entered and exited correctly for the equipment outago time .2 Unit 1 Reactor Trio Insoectios. Scooe The inspectors observed and assessed a reactor trip on Unit Observations _ and Findinos On October 24, at approximately 9:17 a.m., Unit 1 automatically tripped from full power. In the control room, operators had observed a main condenser low vacuum alarm followed within ten seconds by the automatic trip. The plant responded to the trip as designed and there were no complications. The inspectors responded to the control room and observed the performance of Emergency Operating Procedure, EOP-0, " Post Trip Immediate Actions," and EOP 1, " Reactor Trip." Following the trip, the operators observed that a main condenser vacuum breaker had fully opened, causing a loss of main condenser vacuum. Because the main condenser was not available, the reactor was stabilized in Hot Standby using auxiliary feedwater and steam generator atmospheric dump valves. The control room supervisor appropriately assumed an oversight position and followed control of the transient and execution the emergency operating procedures. Periodic status briefings were held with the operators with a notable briefing during the transition between EOP-0 and EOP 1. Prior to exiting the emergency procedures, the vacuum breaker was shut, vacuum was restored, and main feedwater was restored to supply water to the steam generators. The inspector considered the operator actions in response to the trip and to implement the emergency operating procedures to be very good. BGE reported the trip to the NRC in accordance with 10 CFR 50.72(b)(2)(ii).


A Significant incident Findings Team was assembled to review the trip, to determine the root cause, and to recommend appropriate corrective action The root cause was determined to be a poorly completed wire termination for the vacuum breaker handswitch in the control room. A loose strand of wire extemal to the termination had contacted an adjacent powered contact causing a seal-in contact to close in the vacuum breaker control circuit, opening of the vacuum breaker. As corrective action, BGE initiated a 100 percent inspection of the type of electrical connection that had caused the problem, initiated a procedure upgrade to ensure wire terminations were done correctly, and implemented training on the cause and corrective actions for the problem.
All pending changes to the UFSAR with regard to this issue have been completed. We plan to implement the Nuclear Energy Institute guidance regarding 10 CFR 50.59 by June 30,1998.
 
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A'ITACHMENT (2)
NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-02 B. Calvert Cli[fs Technical Specylcation 6.4.1 states that written procedures be established and implemented, covering the activities referenced in Appendix A of NRC Regulatory Guide 1.33, Revision 2, datedFebruary 1978. The regulatory guide includes in Section 6 (r), Proceduresfor Combating Emergencies and Other Sigmficant Events, including, Other Expected Transients that may be Applicable.


On October 25, when the cause of the reactor trip was known and corrected, a plant startup was initiated. Full power was reached on October 26, and there were no complications to the startup, Conclusions The inspectors observed the BGE response to an automatic trip of Unit Operator actions were very good and included completion of the appropriate emergency operating procedures, periodic status briefings, and detailed evaluation of plant conditions. BGE did a thorough review of the transient and  >
Contrary to the above, as of October 15,1997, BGE had neither established nor implemented a procedurefor combating a spillfrom an ammonia storage tank located within the protected area boundary. Specylcally, followihg a postulated ammonia spill, actions for combating the spill including alignment of control room ventilation, personnel response, and the need for self-contained breathing apparatus, had not been established into written procedures.
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af ter the csuse of the trip was understood and corrected, a plant startup was authorized by management. The plant was restarted and returned to full power without complicatio Operational Status of Facilities and Equipment 02.1 Enaineered Safety Feature Systern.Wr;kdowns (71707)
The inspectors performed walkdowns of accessible portions of the Unit 2 emergency diesel generators and the combined control room heating, ventilating, and air conditioning (HVAC) system. Equipment configuration was consistent with plant drawings. Equipment material condition and housekeeping in the areas were good. Several minor discrepancies were brought to BGE's attention and were corrected. The inspectors identified no safety concerns as a result of these walkdown .2 Control Room DeficiencJgg Scoon Tha inspectors reviewed BGE Operations Administrative Policy 93-7," Control Room Deficiency Reduction Program," and its implementatio , Observations and Findinos The operations department had assigned a senior reactor operator the collateral duty of coordinating the control room deficiencies program. One program goal was to have the control room deficiencies planned and scheduled to work within three weeks of identification. The control room deficiency coordinator trended the deficiencies and issued monthly status reports which were reviewed by operations management. BGE management specified that issues affecting safety be repaired on an expedited schedul .
The inspectors reviewed the trend for the previous 18 months and compared the current trend to 1996 results. The inspectors observed that, as expected, the number of control room deficiencies were reduced during outages and trended upward between outages. In September 1996, BGE had approximately
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I. ADMISSION OR DENIAL OF THE ALI.FGED VIOLATION Baltimore Gas and Electric Company accepts the violation.
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40 control room deficiencies and met their goal of less that 55 deficiencies, in rarly 1997, BGE established a more aggressive goal of less than 35 total control  i room deficiencies. The inspectors noted that the September 1997 total of 55 control room deficiencies was higher than the September 1996 total. Most of the deficiencies required unit shutdown for repair. However, the inspectors  ,
II. REASONS FOR THE VIOLATIQN Engineering and chemistry procedures were not adequate to ensure changes to chemhal concentrate:ns, quantities, or storage conditions within the protected area were assessed to determine if changes to emergency procedures were required. As a result, the personnel responsible for the development of emergency procedures used to respond to possible ruptures / breaks in the ammonia tank were not notified of the potential need for a chemical-specific response procedure for the new ammonia tank. '' ''
noted that the September 1997 total reflected BGE's recent efforts to reduce the  '
deficiencies from a recer,t peak of 72 and included the correction of 17 control room doficiencies during the Unit 1 reactor coolant pump seal replacement outag The inspectors reviewed the outstanding r ontrol room deficiencies and determined that no single item in the backlog represented an immediate safety concern. The inspectors noted that those items with higher safety significance
:  were repaired in an expedited manne .
i Conclusions The inspectors found that while BGE had not met their established goals for number of control room deficiencies, efforts to reduce the total number of deficiencies had been aggressive. No existing deficiency represented an immediate safety concern. BGE had focused management attention to ensure that control room deficiencies when considered in ' heir aggregate did not become a safety concer .3 Use of Self Contained Breathino Aooaratus ISCBAs) Insoection Scooe The operational readiness of plant operators to use self contained breathing apparatus was assessed, Findinos and Observations Self contained breathing apparatus were provided near the control room to be used in event of a radiological emergency. BGE told the inspectors that in some scenarios, breathing apparatus would be necessary to protect operations personnel 45 minutes following an accident that included a significant  ,
radiological release. On questioning by the inspectors on the readiness vf the control room for hazardous material spills, BGE reviewed the engineering assessments that had been completed for ammonia storage and responded that the SCBAs could be used during hazardous material spills or fires; however, BGE told the inspectors that no amount of hazardous material that would require SCBA use was stored in the Calvert Cliffs protected are The inspectors observed that most operators were clean shaven; however, a number of operators wore beards or other facial hair that would inhibit immediate respirator use. The inspectors were informed that razors were available for personnel to allow shaving if needed for respirator use. On
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Revisions 20 and 21 have been processed to Emergency Response Plan Implementation Procedure 3.0, .
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  "Immediate Actions." These revisions changed Attachment 19, Hazardous Material Release / Spill. Steps have been added to Attachment 19 to assess Control Room habitability for the presence of ammonia or any other chemical at the onset of a hazardous material release / spill. Action is prescribed in the event a chemical odor is present. Additionally, this revision identifies the location of respiratory equipment should it be needed.
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questioning, some operators did not know the location of the self contained breathing apparatus. Also, instructions on how to effectively don and use the breathing apparatus were not provided with the kit Based on inspector questioning, a senior reactor operator demonstrated donning an SCBA. The operator, from memory, successfully used the apparatus in four minutes; however, the operator did not check the leak tightness of the mask and did not check t'ne low pressure alarm prior to activating the SCBA. These checks were specified in BGE training manual for SCBA use. The senior reactor operator stated that although annual written examinations on SCBA use had
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Special training has been provided to Operations personnel on the use of self-contained breathing apparatus. This training identified the locatica of self-contained breathing appsratus and provided practical experience with self-contained breathing apparatus donning and activation. The object of this special training was to promptly re-familiarize operators in the use of self-contained breathing apparatus.
been completed, practical SCBA training had not been offered for five year Plant operators that were members of the fire brigade regularly used SCBAs in ,
trainin Following questioning by the inspectors, BGE specified operators to be clean  $
shaven and to have practical training on SCBA use. BGE also initiated a review to determine if the need for SCBAs could be eliminated.


- Conclusions The inspectors determined that licensed operator preparedness for use of self-contained breathing apparatus was weak. A number of operators did not know the location of the equipment, some operators wore facial hair that would inhibit SCBA use, and some operators had not traineel with the equipment for up to five years. BGE responded to inspector concerns by establishing a practical training
l  Self-contained breathing apparatus training program will be revised. The revised program will include practical experience with self-contained breathing apparatus donning and activation on an annual basis.
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plan for SCBAs and initiated a review to eliminate the need for SCBAs for licensed operators.


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05 Operator Training and Qualification 05.1 General Scoce (71001)
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A scheduled inspection of the Calvert Cliffs' licensed operators' requalification program was conducted from October 20 24,1997, using NRC inspection procedure 71001. The scope of the inspection included the observation of the annual operating exams administered to one operating and one staff crew of
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,  licensed operators, the review of previously completed annual exams, remedial actions taken for exam failures, and reactivation of inact!ve licenses. The annual examination consisted of a static simulator and classroom written examination, simulator scenarios and job performance measures (JPMs), which were -
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ATTACHMENT (2)
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NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-02 IV. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID   FURTHER VIOLATIONS To avoid further violations of this nature, revisions will be made to appropriate engineering and chemistry procedures. Provision will be made to initiate an assessment of chemical spill response procedures any time analysis determines that greater than 50 percent of a chemical's toxicity level can be realized in the Control Room. The assessment will evaluate whether additional measures are needed for Control Room response to the chemical in question.
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05.2 Exam Contant
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        , insoection Scoos    ,
The inspectors reviewed the annual written and operating examinations for the '[
licensed operators being examined during the inspection. Also reviewed were r previously administered exams and weekly training quizze l l    .
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The inspectors reviewed the written exams administered during the week and found the questions to be of good quality with an appropriate mix of high and ;
low cognitive level questions. Both Parts A and B written exams were  -;
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between different examination ;
The inspectors reviewed and witnessed the performance of several simulator and i in-plant JPMs. The JPMs were relevant to operator tasks, were consistently administered by different evaluators, were technically sufficient to discriminate i operator abilities, and were apprupriately evaluated to identify weaknesses in l  performance. However, there were some NRC identified concerns regarding JPM !
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construction that were brought to the attention of BGE management. These i
;  concerns included: 1) not identifying all critical tasks, 2) designating some JPM - i
*  steps as critical that should not have been, and 3) not including evaluator cues in many instances for inplant JPMs.


l  The inspectors reviewed several simulator scenarios that were given to one operating and one staff crew.. The scenarit,s were challenging and met the ,
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criteria set forth in the examiner standards. The scenarios were diverse and
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utilized variously abnormal and emergency operating procedures.
V. DATE WHEN FULL COMPLIANCE WIIL BE _ ACHIEVED Full compliance was achieved with the revisions to Emergency Response Plan Implementation Procedure 3.0, Attachment 19.


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l Conclusions 4 The f acility had developed annual licensed operator requalification exams that !
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effectively tested the knowledge and abilities of alllicensed operator .3 Exam Administration and Evaluation Inspection Scooe The inspector observed one operating and one staff crew complete two sections i of the. written examination, perform at least two simulator scenarios, and perform five job performance measures (JPM). The inspector also reviewed the facility evaluation of both crew and individual operator performance, i
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7 Observations and Findinas The crews ard individuals passed their operating and written examination Crew and individual operator performance during the conduct of the simulator scenarios was good Communication, for the most part, was very good. Peer checks were conducted frequently in an effort to ensure that all control board manipulations were carried out correctly. Crew briefings were also held frequently. Individual and crew performance was appropriately evaluated by operations and training evaluator During one scenario, the senior shif t supervisor displayed such a dominant role throughout the scenario that the f acility evaluators were unable to effectively evaluate the performance of the control room supervisor or the reactor operato The decision was made to delay final performance evaluations for these two operators pending their participation in another scenario during the next week's annual exam. The inspectors agreed with this decisio During a previous NRC annual requalification inspection, as detailed in inspection Report 317 & 318/9510,it was noted by the inspectors that a management representative from operations was not present during the simulator exams and that f acility evaluators did not provide detailed results of the simulator exam until alllicensed operators had been examined and the results reviewed by management. The NRC stated that this long delay could reduce the effectiveness of the evaluations. The inspectors noted during this inspection that operations management was present during the conduct of the simulator exams for the operating crew. An operations representative was scheduled to observe the performance of the staff crew, but was unable to be present due to a schedJIing conflict. Operations management stated that it is now common policy for operations management to be present during all simulator examination In an effort to address the inspectors' concern regarding simulator debriefs, the facility instituted a policy to perform debriefs immediately following the completion of each scenario. These debriefs consisted of not only informing each individual and crew of pass /f ail results, but also pointed out what they did incorrectly and what the correct actions should have been, The inspectors stated that the timing of this debrief was inappropriate because it transferred the setting from an examination mode to a training mode. Providing training in the middle of an exam could inadvertently provide the knowledge needed by certain individuals necessary for successful completion of subsequent scenarios, or other segments of the exam, and thus distort the evaluation of skills and abilities. The inspectors stated that debriefs should be provided as soon as possible after an individual's entire exam has been administered, but not anytime prior to completion of the entire examination phase for each individual. Facility management stated that they had misinterpreted the pievious inspector's concern and that they would again address the area of debriefs and make the appropr! ate changes to correct this area of concer ._  _ _ _-.
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A'ITACHMENT (3)


Overall performance of JPMs was acceptable. As noted above concerning scenario debriefs, the same occurred during the performance of JPMs. JPM debriefs, including incorrect actions were discussed with the operators following the completion of each JPM. Again, the inspectors stated that this was inappropriate because it provided training during an examination phase. The inspectors also noted that each JPM task standard, an essential element to a systematic approach to training (SAT) based training program, was provided to each c serator prior to their performing a JPM. This information is appropriate for JPM construction; however, it is inappropriate information to be given to the operator. Knowledge of the task standard can be utilized by any individual to indicate the success path necessary to satisf act 3rily complete a JPM, an inappropriate cue. Facility management acknowledged the inspectors' concern and stated that appropriate ections would be taken to address this concern during future examination ,
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-04    l C. Calvert Cli[fs Technical Specification 6.4.1 states that written procedures shall be established and implemented covering the activities recommended in Appendix A ofNRC Regulatory Guide 1.33, Revision 2, February 1978. Regulatoiy Guide 1.33, Section 7,(e)(4) provides for radiation protection proceduresfor contamination control.   ~
During the administration of the static written exam, which is administered in the
Contrary to the above, as ofNovember 1,1997, BGE had neither established nor implemented a procedure that provided contamination controlfrom laundered and re-used anti-contamination  ;
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simulator,it was noted that seven opcrators participated in the first session, and eight operators participated in the second session. The inspectors also noted that there was only one proctor present to monitor and address questions during both test sessions. The inspectors questioned the ability of one proctor to maintain an awareness of allindividuals in this type of test environment, in an effort to maintain examination integrity, the inspectors stated that for this large of a class, there should be at least two proctors. Again, the facility agreed to make the necessary adjustments based upon further evaluation. The inspectors did not identify any indication of examination compromis The evaluations by training and operations department evaluators were effective for those portions of the exam observed by the inspector. The inspectors agreed with the 4cility evaluations. Documentation of test results appeared adequate in all instances, Conclusions The annuallicensed operator requalification exams were administered and evaluated acceptably; however, program enhancements were warranted in the areas of test result debriefs, JPM information provided to the operators, and static exam administratio .4 Continuina Trainina The inspectors reviewed several Calvert Cliffs licensee event reports (LERs) that occurred in 1996 and 1997 in an effort to determine if any of the events were a result of inadequate training. The LERs reviewed did not indicate any deficiencies in the knowledge level of individuals or inadequate training provided by the training department. The facility recently developed and has been using performance indicator graphs for crew and individual performance during examinations and evaluations. Each crew was evaluated against various performance categories similar to competencies listed in the NRC examiner


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,    l I. ADMISSION OR DENIAL OF TIIE AII FGED VIOLATION Baltimore Gas and Electric Company accepts the violation.
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standards. Each crew shift rating was compared to the average of all crew shifts and each individual crew member was compared to the overall crew averag Should an average for a crew or individual be lower than the overall average to which the results are compared, operations or training management can initiate remedial training as they deem necessary to enhance the knowledge level of a crew or individual to bring them in I;ne with the average. The Calvert Cliffs training department had implemented a continuing licensed operator training program that met administrative and regulatory requirement .5 Remedial Trainino The inspectors reviewed remedial actions taken for those licensed individuals who had f ailed any portion of their weekly training evaluations or their annual toqualification exam. In this instance, the inspectors reviewed the remediation documentation for five individual f ailures of a weekly written quiz, one individual f ailure of a weekly simulator scenario evaluation, and two individual f ailures during the annual simulator exam scenarios. Documentation of remediatior'
II. REASONS FOR THE VIOLATION The Radiation Safety Procedure (RSP) 2-406, Revision 2, Laundering of Contaminated Clothing, did not l describe actions to be taken by equipment operators when stated acceptance criteria were exceeded, other I than to report the results to a Radiation Safety supervisor. The procedure lacked criteria for increasing the sample size or dispositioning laundry when a high failure rate of monitored clothing was observed. l The failure rate was used to assess the laundry vendor's performance. The contamination levels detected l
included a review of areas of weakness with the individuals and a retake of another exam. In allinstances, the individuals passed their retake examination The inspector concluded that the Calvert Cliffs' training department had taken appropriato action in regard to those individuals who had f ailed any portion of their annuallicensed operator exam. For those failures reviewed by the inspector, appropriate remedial action had been taken, and documentation was acceptabl .6 License Reactivation The inspector reviewed the f acility's program for restoration of active operator license status following inactivation and found the program to be acceptably documented and administered. The records of three licensed operators, whose licenses had been recently reactivated, were reviewed. The inspector noted that the records were complete and reactivation requircments had been met in accordance with administrative and 10 CFR 55.53(f) requirements. The inspectors determined that the f acility had appropriately implemented the program and regulatory requirements for reactivation of licenses for operators at Calvert Cliffs Unit 1 and Miscellaneous Operations issues 0 (Closed) Unresolved item 50-317&318/95-10-01: Training facility did not document individual operator evaluations except when a failure occurred. The inspectors reviewed current and past simulator evaluations and determined that the f acility evaluators were performing and documenting individual evaluations in additir,n to crew evaluations. Based upon this review, the item is e . _ _ _ _ _ . .
on clothing failing the monitoring was not assessed to determine if a personnel hazard existed or if the l
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acceptance criteria'for laundering of anti-contamination clothing (no significant skin contamination) I could be exceeded. gDuring/Aprih1997,? Radiation SafetyfTechnicians and contractor' :personnel performing Isundry monitoring in accorda'nce Wth'RSP-2-406 failed to document the high rate of failure
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of protective clothing (primarily boots of various sizes), returned from a laundry vendor. The personnel failed to elevate the issue to the appropriate level of supervision for a decision on corrective actions and the dissemination ofinformation to affected site personnel. The NRC Resident Inspector identified other dates in April, May, and August 1997, where during the monitoring of the laundry, numerous articles failed the monitoring threshold / acceptance criteria.


08.2 (Closed) Unresolved item 50 317&318/95-10-02: Not requiring attendance at all requalification training and individuals missing training. The inspectors reviewed records of participation (by attendance)in the licensed operator requalification training program and discussed this area with facility management. In accordance with f acility procedures and management expectations, alllicensed operators were required to attend all continuing training sessions. The inspectors reviswed the tracking process for five individuals who had missed occasional training sessions the past year, it was determined that the facility adequately tracked and followed up on the missed training sessions. Missed classes were made up by attending either subsequent shift training classes or viewing video sessions of previously conducted training. The inspectors determined that the training department had adequately tracked missed training classes and that individuals routinely made up training that they had missed. Through a review of quarterly operations and training interface meetings, the inspectors noted that continued emphasis was being placed on the importance of attending all scheduled classes. Based upon this review, this item is closed, ll< Maintenance M1 Conduct of Maintenance M 1.1 General Comments inspection Scope (62707)
III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED The following immediate corrective steps were taken:
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 of portions of the following work activities:
A. An issue report (IRI-041-829) was written on November I /,1997, and a procedural change
MO2199700634 23 Saltwater Pump Motor, Breaker, and Controls MO2199602803 Repair Expansion Joints for Unit 2 Diesel Rooms M01199700292 Replace Seals and Boarings on 1 A EDG Prelube Pump M01199704163 Boroscope 1 A EDG Cylinders Observations and Findinns The inspectors found that the 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 inspectors noted that an appropriate level of supervisory attention was given to the work. The BGE system engineering report cards discusud problems, maintenance rule status, action plans for systems with lower ratings, and problem trendin . _ _ .- - . _ _ ___ - _ - - . _.
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B. A formal root cause analysis for this event commenced.
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The inspectors were informed by BGE that a leak repair activity for the Unit 1 high pressure turbine casing had been stopped by the quality assurance department on September 30. A Calvert Liffs Nuclear Perforrnance Assessment Department inspector had identified during the pre job briefing that Calvert Cliffs Maintenance Procedure LR 1,"On-line Leak Repair to Pressure Retaining Components," had not been used in developing the leak repair work order. Also, some considerations in procedure LR 1, such as a fire protection assessment, the volume of sealant allowed, and the rpecified injection pressure for the sealant had not been evaluated by BGE engineering. Instead, a vendor procedure had been used to plan the work and the involvement of BGE engineering was minimal. Following the work stoppage, plans for the leak repair were assessed by Oalvert Cliffs engineering, appropriate procedurcs were imptomented, and the job was completed on October 7,1997, without problem A reactor trip was caused by an improper termination on a ma.n condenser vacuum breaker control switch. As corrective action, BGE inspected similar electrical terminations and some additional problems were found and correcte A procedure change was made and training was conducted to prevent recurrence. (See 01.2) ConclusioD1 in general, maintenance was conducted safely and in accordance with approved procedures. Workers were knowledgeable and pe-formed work effectively. A leak repair activity on the high pressure main turbine was initiated without normal engineering assessment. The effort was stopped by the BGE nuclear plant assessment department af tor identification that fire protection, injection pressure, and injection volume had not been assessed. The NRC inspectors considered the efforts of the BGE nuclear performance assessment department to be aggressive and prudent. Initial maintenance department preparations for the high pressure turbine leak repair were poo M1.2 Routine Surveillance Observations The inspectors observed and reviewed selected surveillance tests to determine whether approved procedures were in use, details were adequate, test instrumentation was properly calibrated and used, technical specifications were satisfied, testing was performed by qualified personnel, and test results satisfied acceptance criteria or were properly dispositioned. Tests that were inspected included:
C. An immediate change to RSP 2-406 was implemented on November 25,1997, to
STP O 88-2 Test of 2B DG and No. 24 4Kv Bus LOCl Sequencer 0130  Nuciear instrument - Daily Survel: lance / Calibration STP-0 73A-1 Saltwater Pump and Check Valve Quarterly Test STP-F-490 Fire Detection Functional Test (Smoke)
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STP-F-76 Staggered Test of Electric Fire Pump STP-F-696 Diesol Pump Flow Test
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incorporate actions that included instructions to expand the sample size of monitored articles when an acceptable failure rate is exceeded. This procedure was also revised to provide instructions related to appropriate disposition of the monitored articles. The
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procedure does not allow release of anti-contamination clothing for use in the radiological !
controlled area until monitoring is completed for the appropriate articles. l D. Awareness training was given to all Materials Processing personnel concerning the specifics of this issue.     *
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ATTACIIMENT (3)
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NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-04 Since the immediate change to RSP 2-406 went into effect on November 25,1997, we have had no similar events at Calvert Cliffs.
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The observed surveillance testing was performed safely and in accordance with approved procedures. Pre test briefings included means of communication, test
IV. CORRECTIVE STEPS THAT WII.I. BE TAKEN TO AVOID  FURTHER VIOLATIONS We are revising the appropriate procedures to incorporate an improved statistical sample determination inspection criteria and frequency. Additionally, the requirements for actions to be taken by both workers and supervisors, when acceptance crit'eria are exceeded, will be reviewed and revised throughout the Radiation Safety Procedures as part of the procedure upgrade initiative. All appropriate Radiological Protection personnel will be trained on the revised procedures. We will conduct an effectiveness review of the revised procedures, as appropriate. If additional corrective steps result from the root cause analysis, they will be implemented, as appropriate.
  - control details, and contingency actions. The inspectors noted that an  j appropriate level of supervisory attention was given to the testing depending on  !
 
,  its censitivity and difficulty. For fire protection system testing, the fire and safety i
V. DATE WHEN FULL COMPLIANCE WIIL BE ACHIEVED Full compliance was achieved on November 25,1997, when an immediate change to RSP 2-406 was implemented.
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personnel were well organized and knowledgeable about the fire protection  i system. The procedures were clear and easily implemented. The fire protection equipment was found in good material condition, i
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1 insoection Scope The inspectors reviewed the Calvert Cliffs on site storage of liquid ammonia.


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The inspectors reviewed the Calvert Cliffs Updated Final Safety Analysis Report (UFSAR), concerning the onsite storage of toxic chemicals. UFSAR Section 1.8, Generic issues, Subsection Ill.D.3.4, stated that the control room  r operators would be adeauately protected against the effects of accidental release of toxic gases. The subsection referenced an evaluation of control  3 room habitability that was reported to the NRC in a BGE letter dated December 30,1980.


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l The December 30 letter to the NRC provided a control room habitability study L  as an attachment. The study stated in Section 2.8 that liquid ammonia was  s
 
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stored in 55 gallon drums,550 feet from the control r.,om intake. Further in i   Section 3.3 of the submittal, BGE stated that in the event of a drum f ailure, the concentration of ammonia at the control room intake would be "30.0 ppm,
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. much less that the ammonia toxicity limit of 50 ppm." BGE concluded in the -
i evaluation that on site ammonia storage posed no hazard to control room personne The inspectors observed that ammonia was stored in a 5600 gallon container
:  outside of the north end of the Unit 1 turbine building, in the vicinity of the tank storage area. The inspectors noted that UFSAR Figure 12,"Calvert Cliffs Site
  . Plan " showed that morpholine was stored at the location where the inspectors observed ammonia storage. BGE informed the inspectors that the 5600 gallon polyethylene tank had been installed in the tank f arm in 1986. At that time,-
BGE did not complete an unreviewed safety question evaluation in accordance i
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ATTACHMENT (4)
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50418/97-06 VIOLATION 97-06-06 D. 10 CFR 20.1501 states that each licensee shall make or cause to be made, surveys that may be necessary to comply with the regulations in thispart, and are reasonable to evaluate the potential radiological hazard that may be present. 10 CFR 20.1204 states thatfor the purpose ofassessing dose, licensees shall take suitable measurements ofconcentrations ofradioactive materials in air in work areas.
 
Contrary to the above, on September 16, 1997, during seal replacement of the 11B Reactor  >
Coolant Pump, the air samples were not collected in a suitable location that would be representative ofthe airborne radioactivity to which afected workers were exposed as necessary to comply with 10 CFR 20.1204 I. ADlWIRRION OR DENIAL OF THE AI.I.FGED VIOLATION    '
Baltimore Gas and Electric Company accepts the violation.
 
II. REASONS FOR THE VIOLATION The reasons for this violation are as follows:
A. Personal Air Samplers were not used to monitor for potential air borne radioactivity as there was no clear management expectation to use these instruments.
 
B. 'Ihe Radiation Safety Technician, at the job site, did not use conservative decision-making :
to position the air sampler in the location where the. highestLradioactivelairbornei M y contamination could potentially be present.
 
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III. CORRECTIVE STEPS THAT HAVE RFEN TAKEN AND RERULTS ACHIFVED The following immediate corrective steps were taken:
A. An Issue Report was initiated on September 18, 1997, documenting the event and the immediate actions taken.
 
B. Affected personnel were whole body counted. The results showed that each affected worker received less than 0.1 percent of their annual limit of intake.
 
C. A root cause analysis of the event was commenced.
 
D. Radiation Safety Technicians were trained on the use of the Buck Simple Sampler Personal Air Samplers, and this instrument is being employed on designated jobs to collect breathing zone air samples. This training included clearly defined management expectations on the use of personnel air samplers.
 
No similar events have occurred at Calvert Cliffs since September 16,1997.


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with 10 CFR 50.59. The inspectors observed that a BGE design checklist accompanying the modification which installed the tank had been checked *Not Applicable" for a review of the Final Safety Analysis Repor .
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In 1996, because the existing storage tank had degraded from ultra violet
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ATTACIIMENT (4)
exposure, DGE initiated the replacement of the ammonia storage tank with an upgraded 8500 gallon ammonia storage system. The new system included a secondary spill containment, a localleak detection monitor, and a manifold for  j filling and venting the tank, in preparation for the installation of the 8500 gallon system, BGE reviewed the effects of onsite storage of ammonia for the 5600 gallon tank in June 1996. A .
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BGE calculation completed at that time showed that the peak concentration of  l ammonia in the control room following a worst case spill of a 5000 gallon tank containing 11 percent ammonia would be 137 pprn. A BGE engineer f amillar with the calculation told the inspectors that the peak level of ammonia would persist for about 30 minutes until the ammonia dissipated and that a number of conservatisms remained in the evaluation. BGE reconclied the difference between the 5000 0allon calculation and the actual 5600 gallon tank capacity by stating that the existing tank was never filled above 3500 gallon The GGE control room habitability evaluation provided toxicity limits from the Hazardous Chemicals Data Book (Weiss) of 100 ppm for 30 minutes exposures and 500 ppm for 10 minute exposures. The Material Safety Data Sheet provided by the ammonia supplier st sted that the immediate Danger to Life and Health limit (IDLH) was 500 ppm 8"d specified respiratory protection using self-contained breathing apparatus 'or longer term exposures at 250 ppm concentration. Another reference, the Johnson Matthey Data Book, stated that brief expuures to concentrations of 5000 ppm ammonia could be lethal. The June 1996 BGE review concluded that ammonia at 137 ppm peak concentration in the control room would not pose a toxic hazard following a worst case spill.
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-06 IV. CORRECTIVE STEPS THAT WIIL BE TAKEN TO AVOID    FURTHER VIOLATIONS The following corrective steps will be taken to avoid further violations:  _
A. Procedures are being revised to strengthen criteria for taking representative air samples.


The engineering service package for installation of the 8500 gallon tank had been appro red for installation. However, the 10 CFR 50,59 screening report that accompanied the service package did not evaluate applicability to UFSAR Section 1.8 or Figure 12. Also, the engineering service package did not provide for an ammonia tank leak detection alarm or ammonia concentration readout instrumentation in the control room. The screening report answered
B. All Radiation Safety Technicians will be trained on this event and the importance of ensuring that representative air samples are obtained.
  "No" to the question, "Will the proposed activity result in a change to the safety analysis report description of the design, function, or method of performing the function of any other structure, system, or component described in the SAR?". The negative answer was based, in part, on the October 1996 control room habitability calculation, which concluded that a toxic hazard was not created by the new tank. The screening report did not state that the increase in the volume of the storage tank did not involve an unreviewed safety question. The screening toport restated the conclusion of the June 1996 engineering calculation that the ammonium hydroxide solution would not
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C. We will conduct an effectiveness review of the training diset.ssed above.
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If additional corrective steps result from the root cause analysis, then they will be implemented as appropriate.
constitute a toxicological hazard to the control roo The inspector considered that the October 1996 review for installation of the 8500 gallon ammonia storage tank circumvented the 10 CFR 50.59 proces '
Specifically, the December 30,1980 BGE letter to the NRC, described the storage of 55 gallon drums of ammonia inside the Calvert Cliffs protected are The letter stated a control room peak concentration of 30.0 ppm ammonia and stated a toxicity limit of 50 ppm. BGE justified not completing 10 CFR 50.59 reviews for the storage of increasing amounts of a hazardous material onsite using the habitability calculations done in 19961n the screening reports. The inspectors considered that the increasing amounts of ammonia introduced an increasing hazard to contret room personnel, and that this hazard should have been assessed in accordance with 10 CFR 50.59. Although the BGE determination that the control room habitability remained viable, no specific written safety evaluation had been completed to justify increasing amounts of
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ammonia in the storage location and UFSAR Figure 12 was never update The failure to document a safety evaluation which provided the basis for determining that the increasing amounts of ammonia stored within the Calvert Cliffs protected area was not an unreviewed safety question, was a violation of NRC requirements (VIO 50 317&318/97 06 01).


The inspector also reviewed preparations for an ammonia spill onsite. The inspector noted there was no emergency procedure that specified actions for prots ction of control room or other personnel in event of a toxic chemical spil No pli.ns had been specified for personnel evacuation or use of the breathing apparat is for ammonia spills. BGE informed the inspector that a procedure for i
V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved with the completion of the training on December 16,1997.
combatir 1 a toxic chemical spill on site was under development. Failure to have a procedure to combat a spill of toxic chemicals onsite, including ammonia, was a violation of NRC requirements (VIO 50 317&318/97 06 02), Conclusions The inspectors found ' hat BGE had stored liquid ammonia since 1986 within the protected area boundary without ensuring that the plant was fully prepared for a potential spill of the storage tank contents. An evaluation of the need to place control room ventilation in the recirculation mode and the need to have the operators don respiratory protection had not been considered and procedures for response to an ammonia spill had not been develope BGE had in 1986, increased the toxic material hazard from the on site storage of ammonium hydroxide from 55 gallon drums to a 5600 gallon storage tank, without completing a written safety evaluation. Further, BGE had approved the replacement of the 5600 gallon tar'k with an 8500 gallon tank without a written safety evaluation providing the basis that the change did not involve an unreviewed safety question. Safety evaluation screening reports completed for the tank installations, had not considered UFSAR Section 1.8, or UFSAR Figure 1 2. As a result, the UFSAR had not been update _
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i E2 Engineering Support of Facilities and Equipment
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E Emeraency Diesel Generator Pioina Ooerability Scope The inspector reviewed BGE's actions and response to vendor identified
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  - concerns with welds on the emergency diesel generator lube oil and Jacket water piping systems, Findinas and Observations in a preliminary 10 CFR Part 21 report, dated September 30,1997, the vendor ,
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-05 E. Technical Specification 6.4.1 states that written procedures shall be established and implemented covering the cctivities recommended in Appendix A of Regulatory Guide 1.33, Revision 2.
for the Calvert Cliffs 18,2A, and 2B emergency diesel generators (EDGs)
identified that a weld associated with the lube oil piping on a similar engine had
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f ailed. The piping cracked at a partial penetration weld on piping that experienced high vibration when the engine was running. The vendor noted I that the root cause of this failure was undetermined and the analysis was ongoing; however, the quality of the welds had been questioned.


, BGE had visually inspected the piping for evidence of leakage or cracking in August 1997. Af ter the vendor notification was received, BGE personnel from engineering and analntenance conducted additional visualinspections of each of suspected welds on each of the engines. Vibration measurements were also recorde Engineering developed an operability determination to support continued operation of the EDGs. The operability evaluation noted that the available industry and vendor information suggested that the weld f ailures were due to high cycle fatigue. Based on the measured frequency of the piping and the number of hours on the three opposed piston engines at Calvert Cliffs, BGE engineering determined that a high cycle fatigue failure was unlikel ,
Appendix A ofRegulatory Guide 1.33, Revision 2, &ction 7.e.(1) lists access control to radiation areas including a radiation work permit system. The Calvert Clifs Radiation Safe ~ty Manual, Revision 1, Sections 6.2.I.3.e and 6.2.1.2.6 require that each person working under a specopc special (radiation) workpermit (SWP) comply with the specifc special workpermit in all respects.
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Instructions have been issued for operations personnel to monitor the suspect weld joints during engine operation. BGE planned to develop additional actions in early 1998, based on recommendations from the EDG vendors' ongoing investigation of this issu The inspectors noted that the vendor letter also identified that the jacket water piping could be of concern and questioned why the operability determination only addressed the lube oil piping. BGE stated that although there had been no industry experience with failures in the jacket water cooling piping, the operability determination would be revised to include this piping that was addressed by the vendor preliminary report to the NR .- -- ._ _ _ _ . - - ~ _ ~


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SWP No. 802, task C (remove / replace 11B Reacto- Coolant Pump [RCP] seal) specifiedfull protective clothing dress plus water resistant outer clothing, face shield, kneepads, and extra boots andgloves.
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16 Conclusions The inspectors concluded that BGE was taking appropriate actions to address industry identified concerns with the f atigue of welds on the 18,2A, and 2B emergency diesel generator lube oil and jacket water piping system E8 Miscellaneous Engineering issues E Aircraf t Fliaht Hazards insoection Scoco Recently, the inspectors noted two occasions of low flying aircraf t flights over the Calvert Cliffs site. The inspectors also reviewed the applicable updated final safety analysis report (UFSAR) and individual plant examination of external events (IPEEE) sections related to the hazards from aircraft and discussed the hazards with BGE personne Findinas and Observations The inspectors observed a large aircraft flying on a northwesterly course over both containments at heights estimated to be less than 1000 feet on September 17 and again on September 24. The inspectors notified BGE management and this concern was entered into BGE's issue reporting syste BGE personnelinformed the inspectors that the airspace over the plant was not restricted. However, BGE contacted Patuxent River Naval Air Station (NAS).


The NAS personnel confirmed that pilots are trained to avoid flight directly over the plant and indicated that they would reinforce these instructions in training session UFSAR section 2.2.5.1 indicates that there are three airports within 11 miles of the plant. The airport with the largest aircraf t and most flights is the Patuxent River NAS. The UFSAR indicated that, during approach and departure using instrument flight rules (IFR), the closest flight path would be seven miles from the plant. During a review of the UFSAR in 1995, BGE identified that the flight pattern data in the FSAR was outdated and current IFR flight paths would allow flights over Calvert Cliffs ander certain circumstances. BGE initiated an issue report into their corrective actions system that identified that a potential unreviewed safety question had been identified as a result of the possible increased probtbility of an accident. This issue report remained under BGE review while the IPEEE was complete The IPEEE noted that flights over the plant were rare. The United States Navy Airman's Information Manual directed pilots to avoid flyovers of the plant site
SWP No.11, task C (Inspections and minor maintenance in all areasfollowing a reactor trip)
- and pilots from Patumt River were generally sent on three mile bypass loops around the plant to avoid flyovers. However, three possible routes that fly over the plant were iden4fied. An air traffic count provided by Patuxent River Naval
speciped that in the absence of respiratory protection or facial anti-contamination clothing (Anti-Cs), the thermoluninescent detector be worn on the outside of the Anti-Cs, with the beta window not covered.


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1. Contrary to the above, on September 16,1997 during seal replacement of the 11B RCP, a worker actively performing radiological work as authorized by SWP 802, task C, was not wearing the protective clothing as specsfed by the SWP, in that the individual did not wear
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  - aface shield or water resistant outer clothing though engaged in handling the RCP seal container, andspraying the seal with water to minimize airborne radioactivity.
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I Air Station identified that 214 flights used these routes within the past yea ]
This information was used to calculate a total frequency of an aircraf t crash ,
I from Patuxent River NAS of 4.65x10E-9. BGE found that 74% of the total probability of an air crash impacting vital structures comes from helicopter operations which serve the Calvert Cliffs site. Subsequently, BGE established a limit of six helicopter flights per year and has enforced this limit in their contract with the vendor providing BGE helicopter services. Consequently, the total aircraft crash and the related core damage frequene was determined to be less than 1x10E 6. BGE personnelidentified that by .ie guidance in NUREG 1407, Procedural and Submittal Guidance for 9 Individual Plant Examination of external Events (IPEEE) for Severe * . ant Vulnerab iities, the low probability of thit hazard did not warrant ca cu. ing a resulting core damage frequenc Conclusions On infrequent occasions, aircraf t have been observed flying at low altitudes over the Calvert Cliffs site. Based on the information provided by the Calvert Cliffs IPEEE, the inspectors concluded that the recent flights over the plant did not represent a significant safety hazar IV Plant SuDDort R1 Radiological Protection and Chemistry (RP&C) Controls R 1.1 The Radioloaical Environmental Monitorina Proaram Insoection Scone (84750 2)
The following components of the radiological environmental monitoring program (REMP) were inspected against technical specifications (TS) and the ODCM (TS/ODCM) and NRC Regulatory Guide 4.1, " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants" to assess BGE performance of the program:
- Sample collection from selected sampling locations;
- REMP procedures, the TS/ODCM, and UFSAR, including any changes which pertained to REMP
- Revisions to the program implemented in 1997;
- Annual Reports of the REMP;
- Material condition of air sampling equipment t . automatic water compositors relative to function, operability, and calibration;
- Thermoluminescent dosimeter (TLD) processing and handling;
- The land use census results; and
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The inspector, accompanied by a BGE chemist responsible for implementation and oversight of the REMP, visited selected sites where air samplerc, water compositors, gardens, and TLDs were located. The inspector observed the responsible personnel from BGE's contractor laboratory (Fort Smallwood)
L- ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Baltimore Gas and Electric Company accepts the violation.
exchange air particulate filters and charcoal canisters from the air samplers. The inspector also discussed sampling techniques not observed, such as collection of broad leaf vegetation, fish, soil and sediment. The observed air sampling  '
equipment was well maintained and calibrated and the water compositor was well maintaine '
The intrector compared the sample locations in the ODCM with those in the UFSAR and noted that the UFSAR, Section 2.9, Table 2 47 had not been updatt J to reflect a footnote in the ODCM Table 3.121. The footnote  *
,  explained that cueln sample locations are not "in the general area of", "close to", or "near the sita bi. 'ndary" for a direct radiation sample (DR1), an air satapler (A1), and a food voduct location (Ib4, Ib5, Ib6), respectively. The licensee was in the process if an UFSAR update and completed the 50.59 safety analysis during 'he I ,spection. The change appropriate to the REMP program will be submitted to the NRC in November 1997. The inspector will verify the change during a subsequent inspection. This is an inspection follow-up item (IFl 50 317&318/97 08 03).


The inspector reviewed BGE Chemistry Procedure, CP 234, " Specification and Surveillance for the Radiological Environmental Monitoring Program". The REMP procedure contained appropriate steps for sampling, analysis, program responsibilities and reporting requirements. The responsible personnel reviewed the procedures for technical content, current practices, and requalificatio Procedure revisions were consistent with the current REMP change The analytical results of samples from 1995 and 1996 (documented in the annual reports) and from January through October 1997 were reviewed. The inspector noted that the types and frequencies of analyses were performed as required and the results showed no radiologicalincreases as a result of effluents from the plan BGE replaced the TLD system for environmental monitoring with a more modern system (Panasonic UD 814ASI)in September 1996. BGE performed the
IL REASONS FOR THE VIOLATION On the morning of September 16,1997, a pre-job brief was held with a team of personnel from Major Machinery, the responsible maintenance group assigned to replace the No. IIB RCP seal, Plant Engineering, and Radiation Safety.~ Thejob steps for the evolution were discussed during the brief, along with the specific radiological requirements for each task heading in the SWP to be used (SWP No. 802, !
. . comparison analysis of the previous and current dosimeter types for six months, as required by ANSI N545 and Regulatory Guide 4.13. The inspector reviewed the results and noted the results demonstrated no significant differences in the two dosimeter types and met the ANSI criteria. The handling and processing of the environmental TLDs were reviewed. The TLDs were analyzed by the
  " Removal / Replace Scal" headings A, B, and C). The dress-out requirements for each specific job step ;
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were not discussed.' The Major Machinery craft were signed-in under Section C of SWP No. 802,  ,
chemistry unit of BGE's contractor laboratory, Fort Smallwood. The inspector discussed with responsible personnel handling, processing, calibrating, and maintaining the TLD reader and irradiator. Tiic inspector reviewed the
" Removal / Replace Seal." The dress requirements for this section included full Anti-Cs with water l
  ' associated procedures. The level of detail in the handling, processing, and calibration of TLDs, provided assurance in the ambient radiation measurements around the sit __ . _ _
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l resistant outer clothing, face shield, kneepads, extra boots, and gloves. The Major Machinery Supervisor l- - was signed in under Section A of SWP No. 802, " Support Activities." The dress requirements for this section only required full Anti-Cs. The supervisor was signed in under this section throughout the entire seal replacement evolution.


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During the brief, the team discussed inow the Major Machinery craft would remove the seal, place it in the canister, and remove it from the RCP bay. The team discussed how the supervisor would be inside the pump bay stationed outside of the RCP shroud and would perform support activities such as providing oversight, procedure control, and even the handing of tools to workers inside the shroud. The ,
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team did not discuss or consider the potential for the supervisor to perform job steps that were supposed ,
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Tlio 1995 and 1996 annual reports of the REMP were reviewed to verify the implementation of TS Section 6.6.2. The 1995 and 1996 annual reports provided a comprehensive summary of the resu!!a of the REMP around the site i and met the TS reporting requirements. No omissions, mistakes, or obvious anomalous results and trends were note The 1995,1996, and 1997 land use census were performed during August of 1995 and 1996, and June 1997 as required by the TS/ODCM. Performance of the land use census was thorough and complete. No program changes (e.g.,
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changes in sample locations) were required as a result of the censu The inspector reviewed the wind direction assessments (wind roses) from the past 10 years and compared them to the pre-operational wind roses to detect changes,if any,in the prevailing wind directions. No significant changes were evident. The environmental monitoring control station locations were reviewed against the prevalent directions and the inspector noted that the control locations remained valid in areas that are minimally impacted by the f acility, Conclusion Based on the above review, observation, and discussions, the inspector determined the BGE performance in implementing the REMP continued to be very good. The BGE sampling procedures contained appropriate information and methods compared to industry standards and good practices. BGE demonstrated a good working knowledge and understanding of the intent of the REMP. Sampies were collected from the locations and frequencies specified by the TS/ODC R1.2 _Meteorotonical Monitorina Progu!m Inspection Scope (84730 2)
The fohowing components of the meteorological monitoring program (MMP)
were inspected against TS, the UFSAR, and Regulatory Guide 1.23 commitmunts to assess the BGE performance of the program:
- Calibration procedures and methods;
- Calibration results of wind speed, wind direction and temperature sensors and any related components;
- Operability and maintenance of instruments and equipment; and
- Modifications to the tower or associated instrumentation, Observations and Findinns The BGE Secondary System Engineering Department had responsibility to calibrate and maintain the meteorological mmitoring instrumentatio Calibrations of the wind speed, wind directio and temperature sensors were conducted using the appropriate procedures. The inspector reviewed the calibration results from 1995 through 1997. Calibration methods were acceptable and the results were within the required equipment tolerances in the


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ATTACHMENT (5)
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-05 After entering the containment, two mechanics from the Major Machinery crew went into the shroud area to pull the seal. A third mechanic was stationed outside of the shroud next to the seal canister. The supervisor was stationed outside of the shroud on the opposite side of where the canisterTvas located.
 
The seal was pulled and moved to a location next to the canister. Due to the heat and humidity, the first crew became fatigued and the decision was made to bring in the standby crew. The supervisor, concerned with environmental conditions and exposure from the seal, requested and received permission to perform hands-on job steps associated with removing the seal from the pump bay. This was a deviation from what was discussed at the brief(i.e., the craft was to perform all hands-on activities).
 
Section C of the SWP No. 802 was written to address job steps associated with removing and replacing the RCP seal, but did not clearly state this included all hands on work in the RCP bay. The work supervisor was not appropriately dressed nor signed-in under Section C when he performed hands-on work. If the potential for the supervisor to perform hands-on work had been identified prior to the start of the seal removal / replacement evolution, a decision should have been made to have the supervisor sign in under Section C of the SWP. Instead, the supervisor and the Radiation Safety Technician made the inappropriate decision in the field to allow the supervisor to perform hands-onjob steps under Section A of the SWP.


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III. CORRECTIVE STEPS THAT HAVE BFFN TAKEN AND RFRULTS ACHIFVED Calvert Cliffs procedures RSP l-106 and MN-1-100 both contain guidelines for conducting prejob
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briefs. These guidelines state assigned individuals and specific roles and responsibilities should be discussed during pre-job briefs.


procedures. The meteorologicalinstrumentation was calibrated at the  ;
The Plant General Manager issued specific expectations via a site memo stating roles and responsibilities l l
semlannual frequency, as required by the TS. The physical condition of the equipment appeared to be good. BGE maintained a preventive maintenance  ;
for high radiation area pre-job briefs. Effective December 15,1997, a first line supervisor is expected to: j (1) attend every high radiation area pre-job brief that affects their business function; (2) actively l participate in the brief to ensure success from safety, quality, and coordination standpoints; and (3) l
program to ensure equipment operability. Modifications to the tower and associated instrumentation had been made since the previous inspection. The modifications made included the addition of metal oxide varistors (varying resistors) and surge protectors to reduce the effects of lightning strikes on the l
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provide feedback on how the job went and whether attendance had a positive impact on improving the overall work process within the radiological controlled area. The supervisor is expected to discuss specific roles and responsibilities, survey results, as well as conditions that may require work to be stopped or necessitate the need for contingency plans.    ,
tower and instrumentation, Conclusions
IV. CORRECTIVE STEPS THAT WHL BE TAKEN TO AVOID  FURTHER VIOLATIONS To ensure all personnel who perform hands-on work in the RCP bays associated with the removal and replacement of an RCP seal are adequately dressed, future RCP seal replacement SWPs will be written to clearly state the specific activities that can be performed under each section of the SWP.
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The inspector determined that overall, the BGE performance of maintaining and
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calibrating the meteorological m;,nitoring instrumentation was very goo R1.3 Secondary Chemistry Control Imolementation Chanae  j lamection.Sagan The inspectors reviewed changes to the BGE secondary chemistry control program,
, Findinas and Observations
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On October 2, BGE implemented a change to the chemicals used in the condensate and feedwater systems with the introduction of dimethylamine (DMA) into these process streams (in Unit 1 only) to enhance corrosion contro DMA is a low molecular weight organic amine which is highly volatile and has been used successfully at several other nuclear plants for secondary chemistry control. At a recent plant safety review committee meeting observed by the inspectors, BGE engineers indicated that the primary benefits of DMA use would be a further reduction in iron transport to the steam generators (S/G) and lessened fouling of the secondary side of the S/G tubes. The engineers also
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pointed out that DMA's reaction with copper alloys could result in an increase of copper transport to the S/Gs, and copper is an aggressive corrosive towards S/G
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tubes. The insoectors noted that committee members displayed a conservative and questionir.g attitude, particularly regarding the safety aspects of DMA's potentially deleterious effect The inspectors questioned whether personnel safety, including control room operators, had been evaluated should a spill of DMA occur. BGE indicated that
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a calculation (Calculation CA03489)had been performed which damonstrated that the dilute concentration to be used (2%) was not a fire or toxicological hazardi To further reduce the risk, only one 335 gallon container would be permitted in the turbine building at any given time. The inspectors reviewed the test procedure (ETP 97-067," Introduction of DMA mto Unit 1 Feedwater") and
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the controlling chemistry procedure (CP 217, " Specifications and Surveillance:
Secondary Chemistry") and concluded that they contained, as appropriate,-
personnel safety precautions and warning . _
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Site Supervision will conduct tailgate training with workers who have access to the radiological controlled area to stress the importance of SWP adherence in the field, Additionally, we are currently conducting a root cause analysis of this event. Additional applicable ,
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corrective actions will be developed and implemented as necessary.
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21 . Conclusions The inspectors found that BGE had taken adequate precautions for a change in '
the chemical agents added to the Unit 1 secondary syste R2 Status of RP&C Facilities and Equipment Insoection Scopo The inspectors reviewed the BGE programs for monitoring for personnel contamination at the protected area boundary, Observations and Findinas BGE used portal monitors at both the entrance and exit to the protected are BGE told the inspector that the purpose of the monitoring was to ensure that stray contamination was neither brought onto or taken from the site. The inspectors were informed that contamination control for individuals working in radiation areas in the plant was maintained either at the specific job site boundary, at the exit to the auxiliary building, or both. BGE personnel stated that the exit monitors at the protected area boundary served only as a backup and not as a control point. The exit monitoring required a 10 second pause to ensure effective dete: tion of radioactive materia In 1997, BGE identified that some individuals were not pausing at the entrance monitors in the Nuclear Office Facility (NOF). BGE conducted an assessment of the effectiveness of the entrance and exit monitors and determined that a pause should be required to monitor for contamination. To ensure that personnel acted appropriately, BGE stationed radiation controls or security personnel at the monitors until a high assurance of personnel compliance with the pause was established. Additionally, both the entrance and exit monitors were posted that a pause was required and the pause times were extended to ensure that a valid count was completed. The inspectors observed that individuals entering the plant properly paused until the radiation scan was complete. The inspectors also observed that BGE posted a guard at the monitors during outage periods to ensure that contractor personnel were aware of the pause requirement Conclusions The inspectors concluded that the BGE monitoring and control of radioactive material at both the entrence and exit to the plant protective areas was effective for the intended purpos .
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R3 RP&C Procedures and Docurnentation R3.1 Launderina of Contaminated Clothina Insoection Scope The inspectors reviewed the BGE handling and re use of Anti Contamination clothing (Anti Cs). Findinos and Observations in the 1996 Personnel Contamination Report, BGE identified that 21 personnel contamination events had been attributed to contaminated re used Anti C clothing. The report stated that this was an increase from 15 similar occurrences in 1995. As a result, BGE specified that a self assessment of contaminations from Anti C clothing would be conducted. The assessment, which was completed in April 1997, identified a number of weaknesses in the control of laundered anti-Cs, and recommended corrective actions. The assessment concluded that the laundering process was adequate to prevent significant skin contaminations from occurring (above the levelin which BGE procedures required completion of a dose assessment). BGE changed the vendor that provided laundry services et the end of March 1997. BGE informed the inspector that no significant skin contaminations had occurred in 1995, 1996, or 199 The inspectors reviewed a BGE, August 1997 personnel contamination summary, completed by radiation controls personnel. The report stated that 80 personnel contaminations had occurred in 1997 with 16 events attributed to contaminated, re used anti C A personnel contamination was defined as greater than 100 counts per minute above background on an individuals skin or clothing. A contamination was normally detected during personnel monitoring at frisker stations on each level in the auxiliary building or at the personnel contamination monitors at the exit to the auxiliary buildin The inspector was informed that most used Anti C clothing was shipped to an
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offsite vendor for cleaning. Upon return, five percent of the Anti-C clothis was removed for contamination monitoring by BGE personnel. The remaining 95 percent were sont directly to the auxiliary building for use by plant personne BGE stated that the monitoring was used to evaluate the effectiveness of the vendo The inspector reviewed the results of laundry monitoring by BGE. An automated detector system, with a limit of 25,000 decays per minute (dpm) or less to pass the cloth!ng, was used to monitor individual pieces of clothing. Il levels above 25,000 dpm were observed, an alarm would sound and the pieces would be


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l identified as contaminated. Pieces with contamination less that 25,000 dpm   !
were returned to the plant for general use. BGE informed the inspector that  !
25,000 dpm was equivalent to 5000 counts per minutes per 100 square  j
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l centimeters, which was equivalent to five times the BGE free release criteria of  j 100 counts per minute with a 20 square centimeter hand held probe. BGE  ;
ATTACHMENT (5) ;
J  considered less than 25,000 dpm of contamination on used clothing an  i acceptable risk for rt,diation workers wearing anti C clothing in the conduct of radiation wor I A sample of monitoring results were reviewed by the inspector. On April 29,
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-05 V. DATE WHEN FULL COMPLIANCE WILI BE ACHIEVED l    Full compliance was achieved on December 15,1997 with the issuance of the Plant Generil Manager's memo.       l i
'i 1997,84 hoods were tested and 2 failed, 563 cloth shoe covers were tested  r and 2 failed, and 78 coveralls were tested and 8 f ailed. On April 30,209  l Jumbo rubber gloves were monitored and 59 gloves f ailed, and 189 extra large totes were sampled and 113 failed. On May 17,20 large personnel clothing  ;
        .
  (PCS) were sampled, and 11 f ailed,73 red gloves were tested and 23 fnited,  j and 254 Kevlar gloves were tested and 4 failed. Oli August 26,130 hoods were tested and 8 f ailed,60 green boots were tested and 7 failed, and 122  ;
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cloth booties were tested and 2 f aile ,
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The inspector found th:st BGE did not have criteria for increasing the sample size or dispostioning laundry when a high failure rate of monitored clothing was i  observed. BGE informally used the data to assess the vendor. As seen in the some shipments, a large fraction of clothing sampled was above the monitoring limits. Therefore, some shipments would result in a higher likelihood that a personnel contamination would result from contaminated anti C clothin ,
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Additionally, the amount of contamination observed on articles that failed the
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monitoring was not assessed to determine if a personnel hazard existed or if the
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BGE acceptance criteria for laundering of Anti Cs (no significant skin contaminations) could be exceeded.


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Although no significant skin contaminations had been observed, Anti C articles that had been returned to Calvert Cliffs from the laundry vendor were at times
!. contaminated above the limits specified in the Calvert Cliffs procedure for laundering of Anti C clothing. No procedure existed which specified actions to i  be taken when articles were found auove the monitoring limits, including criteria i
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for sample expansion, assessment of the contamination in excess of the limits, and actions to ensure that laundered clothing contaminated above acceptable limits was not made available for general use. The f ailure to develop and implement a procedure for control of laundered contaminated clothing was a  ,
violation of NRC requirements (VIO 50 317&318/97 06 04).    ,
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During the review of contamination events from Anti C clothing, the inspector
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learned of an event that occurred on April 7,1997. The event was documented l  in an issue report and involved an individual with detectable skin contamination, L  - but at a level below the 100 counts per minute definition of a personnel
  ' contamination incides.t. BGE generated the issue report after determining that
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the comamination was greater than 50 cpm but less that 100 cpm and had not been documented in the personnel monitor alarm log.' The inspector was l
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ATTACIIMENT (6)
NRC REGION 1 INTEGRATED INSPECTION REPOR r NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-07 E. Technical Specification 6.4.1 states that written procedures shall be established and implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2.


successfully decontaminated. For this event, the inspector was informed that because the auxilisry building monitors were 10 percent ef ficient for detection of contamination, the individual may have indicated an uncorrected count of about 1640 decays per minute, that when divided by 10 for counter efficiency and when the nominal outage background of 70 counts was subtracted, resulted in a corrected count rate of about 94 cpm. Since the corrected count rate was less than 100 creunts, it would not be a recordable personnel contamination event at Calvert Chtfs. As a result, the inspector was concerned that the actual number of problems resulting from poorly laundered anti-C clothing could be greater than stated on the personnel contamination summary report. As noted above, an issue report was written and BGE initiated changes to the personnel contamination procedure to ensure that contamination events were properly documente c. Conclusiong BGE had not developed and implemented a procedure to prevent personnel contaminations from occurring as a result of contaminated Anti C clothin Although no significant skin contaminations had been observed, Anti C articles that had been returned to Calvert Cliffs from the laundry vendor, were at times contaminated above the limits specified in the Calvert Cliffs procedure for laundering of Anti C clothing. However no procedure existed which specified actions to be taken when articles were found above the monitoring limits, including criteria for sample expansion, assessment of the contamination in excess of the limits, and actions to ensure that laundered clothing contaminated above acceptable limits was not made available for general us The inspector found that some contamination events below the 100 count level wete not documented in the personnel rnonitor log. Not documenting and tracking these events was a poor practice and as a result, ths actual number of problems resulting from poorly laundered anti C clothi 9 could be greater that stated on the personnel contamination summary repor R4 Staff Knowledge and Performance in RP&C a. Srang (83729)
Appendix A ofRegulatory Guide 1.33 Revision 2, Section 7.e.(1) lists access control to radiation areas including a radiation work permit system. The Calvert Chffs Radiation Safety Manual, Revision 1, Sections 6.2.1.3.e and 6.2.1.2.6 require that each person working under a specific special(radiation) workpermit (SWP) comply with the specific special workpermit in all respects.
The inspectors performed a tour of Unit 1 containment and observed 118 raactor coolant pump seal replacement activities on September 16,1997. Also, the inspector observed the initial containment entry following the reactor trip on October 24,199 b. Qhiervations and Fip_ dings Dui : tour of the Unit 1 containment, high radiation area barriers were revL sd and evaluated. These barriers consirted of ladder locks and locked stairway door barricades that were substantial. In addition, during entry to containment and also prior to entering the high radiation area locked door


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SWP No. 802, task C (remove / replace 11B Reactor Coolant Pump seal) specifiedfull protective clothing dress plus water resistant outer clothing. face shield, kneepads, and extra boots and gloves.
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leading to the reactor coolant pump area, radiation safety personnel verified special work permit (SWP) authodzation, electronic dosimeter setpoints, and worker knowledge of these setpoints prior to authorizing entr Af ter the old reactor coolant pump seal cartridge had been removed and placed inside a storage canister, the radiation safety technicians (RSTs) conducted a turnover. The on-coming RST received some information from the outgoing RST. The on-coming RST was generally aware of the seal dose rates although the beta radiation levels were not correctly passed along in the turnover. In addition, the configuration of the seal stored inside a canister in the work area at the time of the turnover had not been surveyed by the c r coming RST and no turnover had been given on the canister dose rates. No instruction was provided that this survey should be psrformed. Later, surveys revealed dose rates of 200 miem/hr on contact and 60 mrem /hr at 30 centimeters. This was a significant radiation sourca on the work platform area (35 mrem /hr) which had not been surveyed by tho responsible RST covering the workers. The oversight in monitoring radiation levels at the work site was a significant weakness in high radiation monitoring coverage of this jo The inspectors observed good control and oversight to prevent foreign material from entering the reactor coo: ant system during the pump seal replacemen After the highly contaminated seal had been removed and placed inside the storage canister, the work supervisor was observed handling the open canister and spraying down the highly contaminated seal with water. This worker was not wearing a set of water resistant protective clothing or a f ace shield as required by Special Work Permit Number 802, task C. This doviation from the SWP requirements was not stopped or corrected by the RST controlling the jo Non-compliance with the SWP was a violation of the Calvert Cliffs Radiation Safety Manual, Section 6.2.3.e (VIO 50-317&318/97-06-05).
SWP No.11, task C (Inspections and minor maintenance in all areas following a reactor trip)
specified that in the absence of respiratory protection or facial anti-contamination clothing (Anti-Cs), the thermoluninescent detector (TLD) be worn on the outside of the Anti-Cs, with the beta window not covered.


During seal replacement activities, stationary low volume air samples were taken at two different platform elevations. The air sample location on the pump seal ,
2. Contrary to the above, on October 24,1997 during an initial containment entryfollowing a reactor trip, two radiation safety technicians performing radiological work authorized by SWP 11, task C, were not wearing either respiratoryprotection or their TLDs on the outside ofthe Anti-Cs, with the beta window not covered.
platform area was placed at the shroud circumference nearest to the platform access ladder. The seal had been removed and rigged out from the opposite
    *le of the shroud from the air sample location. In addition, a small 250 CFM
    . EPA unit was located on the opposite side from the air sample location drawing the seal area air flow away from the air sample. No personallapel air samplers had been provided for the workers on this job. The air sample results indicated 2.124 derived air cencentration (DAC) and 0.04 DAC during seal removal and inspection activit:es, respectively. Due to the air sample location and questioning by the .nspectors, BGE determined that the sample location did not represent the highest airborne radinctivity hazard in the work area. The inspectors considered that the sampling location representec an inadequate survey and was a violation of 10 CFR 20.1501 pursuant to 10 CFR 20.1204 (VIO 50-317&318/97-03-06).


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L ADMIRMION OR DENIAL OF THE ATJFGED VIOLATION Baltimore Gas and Electric Company accepts the violation.
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l IL REASONS FOR THE VIOLATION
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The reasons for this violation are as follows:
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A. The two Radiation Safety Technicians (RSTs) involved with this event failed to follow the requirements stated in the applicable Special Work Permit (No. 97-11), specifically, "in the absence of Respiratory Protection or Facial Anti-Cs, the thermoluminescent detector (TLD)
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is to be worn on the outside of the Anti-Cs." The two RSTs did not practice the "Stop, Think, Act, and Review,"(STAR) principle and did not perform self-checking.


Following the reactor trip that occurred on October 24, the inspectors observed two RSTs making an initial entry into the Unit 1 containment for air sampling.
B. A copy of the applicable SWP (No. 97-1l) was not present at the Unit 1 Containment persoa.el air lock, as required.


,  - The inspectors observed that the RSTs wore no respiratory protection anrf had -
III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED The following immediate corrective steps were taken:
  - their thermoluminescent detectors (TLDs) and other dosimetry inside of their protective clothing (Anti Cs). The RSTs informed the inspector that they were entering containment using Special Work Permit (SWP) Number 11C. Toe inspector observed that the S'NP stated that "In the absence of Respiratory Protection or Facial Anti Cs, the TLD is to be worn on the outside of the Anti-Cs." The discrepancy was pointed out to the Radiation Controls Shift
I A. The two affected RSTs moved their TLDs to the outside of their protective clothing, as required by SWP No. 97-11.
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Supervisor and the Radiation Controls Superintendent. Following the event in a typed statement, the RSTs stated + hat they had not entered the Unit 1 containment because lighting was not available when the inner containment door was opened. For this reason, BGE informed the inspector that a skin dose assessment was not necessary. However, the SWP was applicable when the workers crossed the boundary that leads into the containment building. Non-compliance with the SWP was a violation of the Calvert Cliffs Radiation Safety Manual, Section 6.2.3.e (VIO 50 317&318/97-06-07). Conclusions
  'Although the licensee has tightened the controls for access into high radiation i areas, control of work within high radiation areas was weak. Several problems were observed in work performance during reactor coolant pump seal replacement activities. Specifically, insufficient radiation safety technician turnover of radiological information, an improperly positioned air sampler, and an improperly dress worker was not stopped or controlled by the job coverage radiation safety technician. Two violations were cited involving failure to take-suitable measurements of airborne radioactivity and failure to comply with the requirements of the applicable SW During the initial containment entry following the reactor trip on October 24, two radiation safety technicians were observed by the NRC inspector making a high radiation entry without fo: lowing the Special Work Permit requirement to wear the TLD on the outside of the Anti-C clothing, with the beta window exposed. This was an additional violation of NRC requirement R6 RP&C Organization and Administration R6.1 Oraanization Chanaes and Responsibilities
  .The inspector reviewed organization changes and the responsibilities relative to oversight of the REMP and MMP. No changes in the organ!:ation regarding the oversight of the REMP or MMP were made since the previous inspection in this area. The responsibilities relative to oversight of the REMP and MMP have essentially remained the same. The BGE Chemical Technical Services Department has primary responsibility for conducting the radiological environmental monitoring program aad the Secondary Systems Engineering
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b. An Issue Report was initiated on October 24, 1997, documenting the event and the immediate action taken.
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Department has primary responsibility for maintaining the meteorological monitoring tower. The Fossil Engineering and Maintenance Department Chemistry Unit of BGE's contractor laboratory (Fort Smallwood) were responsible for the sampling and analysis of environmental sample R7 Quality Assurance in RP&C Activities R 7.1 Quality Assurance Audit Prooram a, 'Insoection Scoce (84750 2)
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The following quality assurance audits of the BGE radiological environmental monitoring program were reviewed:
  - 1995 QA Audit Report (Report No. 95 3); and
  - 1996 QA Audit Report (Report No. 96-16).


b .- Observations and Findings The audits were conducted by the Nuclear Performance Assessment Department (NPAD), formerly the Nuclear Quality Assurance Department (NOAD). The audits covered the radiological environmental monitoring program and were conducted by the BGE NPAD staff with assistance from other technical specialists, including a specialist from another utility. Both audits concluded that the Chemistry Department implemented a very good environmental monitoring program. Both audits identified findings. These findings were of minor safety significance and were closed. The next audit in this area will be performed in 199 Conclusions Based on the review of the BGE audits and discussions with an auditor, the inspector concluded that BGE effectively identified and assessed the radiological monitoring program strengths and weaknesses. The audits evaluated the technical adequacy of implementing procedures and TS and ODCM requirements. Performance of the audits was thorough, objective, and of very good qualit R7.2 Quality Assurance of Analvtical Measurements a, insoection Scoce (84750-2)
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The inspector reviewed the quality assurance (QA) and quality control (OC)
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programs of the licensee's Fort Smallwood analytical laborator _-_ _
ATTACliMENT (6)
NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-07 C. A root cause analysis of the event is complete.


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No similar events have occurred at Calvert Cliffs since October 24,1997.
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28 Observations and Findinos The inspector reviewed the programs for QA and OC of analytical measurements for radiological environmental samples to determine whether the licensee had adequate control with respect to sampling, analyzing, and evaluating data for the implementation of the REMP. The Fossil Engineering and Maintenance Department (FF.MD) Chemistry Unit implemented an interlaboratory comparison program, required by technical speciiscations,    .
through continued participation with the Environmental Protection Agency (EPA) drinking water program and a program prnvided by Analytics, incorporated. The inspector reviewed the analytical results. The inspector noted that the results of the quality control and interlaboratory programs were within the established acceptance criteria. The RGE quality control program consisted of measurements of duplicato and split samples. The inspector reviewed the analytical results and ..oted that the results were generally within the acceptance criteria. When discrepancies were found, reasons for the discrepancies were investigated and resolved, Conclusior Based on the above observations, the inspector determined that the performance of the laboratory analyses was excellent and the interlaboratory comparisor, programs were effective. BGE had a good quality control program with respect to sampling, analyzing, and evaluating data for implementation of the REM S8 Miscellaneous Security and Safeguards Activities The inspector reviewed a BGE investigation concerning fitness for duty of a small number of workers at the site. The NRC inspection included review of documents and discussions with BGE personnel. None of the workers involved in the investigation conducted work on safety systems. The inspectors found that BGE had conducted a thorough review and had properly dispositioned all concerns raised during the investigatio ,
F8 Miscellaneous Fire Protection issues During the period, the inspectors conducted walkdowns of varicus fire protection equipment, including fire hydrants, sprinkler piping, hose and nozzle storage boxes, and emergency fire pumps. All of the equipment was in good material condition and no problems were identified. The fire and
  :iafety personnel were well organized and knowledgeable about the fire protection system (See M1.2), the fire protection procedures were clear and easily implemented. The fire protection equipment was found in good material conditio l
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IV. CORRECTIVE STEPS TIIAT WIIL BE TAKEN TO AVOID  FURTHER VIOLATIONS The following corrective steps will be taken to avoid further violations:
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A. Appropriate Radiation Safety personnel will be provided training on using the STAR principle.
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B. Appropriate personnel action was ad ninistered.


V. M_a.Lrm9emtqt Meetinas X1 Exit Meeting Summary During this intpection, periodic meetings were held with the plant general manager and other station management to discuss inspection observations and findings. Ori November 25,1997, are exit meeting was held to summarize the conclusions of the inspection. BGE management in
C. Copies of SWPs will be located at the appropriate areas in the RCA.
        '
attendance acknowledged the findings presente .
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V. DATE WHFN FULL COMPLIANCE WIII BE ACHIEVED Full compliance was achieved on October :4,1097, when the two affected RSTs moved their TLDs to the outside of their protective clothing, as required by SWP No. 97-11.
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        .
e ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED l  E P. Katz, Plant General Manager K. Cellers, Superintendent, Nuclear Maintenance K. Neitmann, Superintendent, Nuclear Operations P. Chabot, Manager, Nuclear Engineering T. Pritchett, Director, Nuclear Regulatory Matters B. Watson, General Supervisor, Radiation Safety C. Earls, General Supervisor, Chemistry L. Gibbs, Director, Nuclear Security T. Sydnor, General Supervisor, Plant Engineering T. Forgette, Director - Emergency Preparednecs M. Tonacci, Chemistry Supervisor G. Barley, Senior Chemist J. Carroll, PGM Alternate B. Putman, NPAD Lead Assesscr Fort Smahypod Laboratory A. Kaupa, Senior Chemist L. Bartol, Senior Chemist R. Lassahn, Supervisor NRQ J. White, Chief, Radiation Safety Branch, DRS INSPECTION PROCEDURES USED IP 62707: Maintenance Observation IP 71707: Plant Operations IP 93702: Prompt Onsite Response to Events at Operating Power Reactors IP 61726: Surveillance Observations IP 37550: Engineering IP 37551: Onsite Engineering IP 71750: Plant Support Activities IP 83750: Occupational Exposure IP 92700: Followup of Written Reports of Events at Power Reactor Facilities IP 92902: Followup - Engineering IP 82701: Operational Status of the Emergency Preparedness Program IP 83729: Occupational Exposures During Extended Outages IP 84750: Radioactive Waste Treatment, and Environmental Monitoring
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- Attachment 1  2 ITEMS OPENED, CLOSED, AND DISCUSSED Ooene &318/97-06-01 VIO The failure to document a safety evaluation for increasing amounts of ammonia in the protected area 50-317&318/97-06-02 VIO Failure to have a procedure to combat a spill of toxic chemicals onsite, including ammonia 50-317&318/97-06-03 IFl UFSAR not consistent with the ODCM, REMP program to be change &318/97-06 04 V!O Failure to develop and implement a procedure for control of laundered contaminated clothin &318/97-06-05 V.O Failure to follow SWP requirements during RCP wor &318/97 06-06 VIO Sampling location represented an inadequate i  survey during RCP wor &318/97-06-07 VIO Failure to follow SWP requirements during containment entr . Closed 50 317&318/95 10-01 URI - Training did not document individual operator evaluations during requalification exa &318/95-10-02 URI Training did not require attendance at all requalification training se::sion *
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LIST OF ACRONYMS USED CFR Code of Federal Regulations DAC Derived Air Concentration (radiation limit)
    .
dpm decays per minute (radiation)-
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EOP-O Emergency Operating Procedure for Post Trip immediate Actions EOP-1 Emergency Operating Procedure for Reactor Trip EDG Emergancy Diesel Generator IPEEE Individual Plant Examination for External Events LCO Limiting Condition for Operation (Technical Specification)
    -
mrem /hr rnillirem per hour NAS Naval Air Station (Patauxent)
RCS, ~ Reactor Coolant System RP&C 9adiation Protection and Chemistry RST Radiation Safety Technician SCBA Self-Contained Breathing Apparatus


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Attachment 1  3 SWP Special (radiation) Work Permit UFSAR Updated Final Safety Analysis Report
: MOV Motor Operated Valve  <
LPSI - Low Pressure Safety injection IR BGE issue Report GA Quality Assurance TLD Thermoluminescent Dosimeter MMP . BGE Meteorological Monitoring Program NPAD BGE Nuclear Performance Assessment Department ODCM Offsite Dose Calculation Manual REMP Radiological Environmental Monitoring Program TS . Technical Specifications
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Revision as of 07:33, 1 February 2021

Ack Receipt of 980105 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/97-06 & 50-318/97-06
ML20248M087
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 06/09/1998
From: Doerflein L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Cruse C
BALTIMORE GAS & ELECTRIC CO.
References
50-317-97-06, 50-317-97-6, 50-318-97-06, 50-318-97-6, NUDOCS 9806120367
Download: ML20248M087 (2)
v • d • e


Text

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June 9, 1998 Mr. Charles Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway

Lusby, MD 20657- 4702 '

SUBJECT: NRC INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 AND NOTICE OF VIOLATION

Dear Mr. Cruse:

This letter refers to your January 5,1998, correspondence in response to our l December 5,1997, letter. l Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.

We appreciate your cooperation.

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Sincerely, Original Signed by:

William A. Cook for Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects Docket Nos. 50-317 50-318 cc:

T. Pritchett, Director, Nuclear Regulatory Matters (CCNPP)

R. McLean, Administrator, Nuclear Evaluations f J. Walter, Engineering Division, Public Service Commission of Maryland

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cc w/ copy of Licensee's Response Letter:

K. Burger, Esquire, Maryland People's Counsel  !

R. Ochs, Maryland Safe Energy Coalition State of Maryland (2)

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9006120367 990609 l PDR ADOCK 05000317

.G PDR ,

0FFICIAL RECORD COPY IE:01 u--_________. - - _ - - - - - - - . - - _ - - _ - - - _ - - - _ -- -- __ -- _-- a

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Charles Distribution w/ copy of Licensee's Response Letter:

B. McCabe, RI EDO Coordinator F. Bower - Calvert Cliffs S. Bajwa, NRR A. Dromerick, NRR L. Doerflein , DRP S. Adams,DRP R. Junod, DRP M. Campion, RI Nuclear Safety Information Center (NSIC)

PUBLIC Region 1 Docket Room (with concurrences)

Inspection Program Branch, NRR (IPAS)

DOCDESK l

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' DOCUMENT NAME: A:\RL970606.CC To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment / enclosure "N" = No copy OFFICE Rl/DRP Rl/DRP NAME SAdams 54 LDoerflein p@ g 03/tt/98 .1937,/98 ,

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DATE r OFFICIAL RECORD COPY

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CIIARLES II. CRUSE Daltimore Gas and Electric Company Vice President C$tivert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby. Maryland 20657 410 495-4455

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January 5,1998 U. S. Nuclear Regulatory Commission Washington,DC 20555 ATTENTION: Document Control Desk SUBJECT: Calvert C:iffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 NRC Region I Integrated Inspection Report Nos. 50-317/97-06 and 50-318/97-06 and Notice of Violation REFERENCE: (a) Letter from Mr. L. T. Doerflein (NRC) to Mr. C. (BGE), dated December 5,1997, NRC Region 1 Integrated Inspection Report Nos. 50-317/97-06 and 50-318/97-06 and Notice of Violation This letter provides Baltimore Gas and Electric Company's response to Reference (a), which identified six violations. Each of the violations cited has been individually addressed as specified in the Enclosure to Reference (a). Individual responses to each of these violations are provided in Attachments (1) through (6).

kC!Tj6&D3 / / 5W

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. Document Control Desk j January 5,1998 l Page 2 J

f Should you have questions regarding this matter, we will be pleased to discuss them with you. I Very truly yours,

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g, /9L STATE OF MARYLAND  :

TO WIT:

COUNTY OF CALVERT  :

I, Charles II. Crtae, being duly swom, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this response on behalf of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

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W i

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I S bsc bed defand ) sworn.thisbefore d day me aof Notary (Public in and for the State of Maryland and County of u ls h v .1998.

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WITNESS my Hand and Notarial Seal: b/h1 AlJ b ltLL Notary Public j My Cemmission Expires: AA 9 Date i CliC/CDS/bjd Attachments cc: R. S. Fleishman, Esqui,e Resident Inspector, NRC l J. E. Silberg, Esquire R. I. McLean, DNR Director, Project Directorate I-1, NRC J.11. Walter, PSC A. W. Dromerick, NRC L. T. Doerflein, NRC 11. J. Miller, NRC

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ATTACHMENT (1)

NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-01 A. 10 CFR 50.59 allows the holder of a license to make changes to thefacility as described in the safety analysis report, wl:houtprior commission approval, unless the proposed change involves an unreviewed safety question. 10 CFR 50.59(b)(1) requires that the licensee maintain records of changes and that these records include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.

10 CFR 50.71(e) requires that licensees periodically update the final safety analysis report to assure that the report contains the latest materialdeveloped.

Contrary to the above, as of Oct'ober 15,1997, the screeningfor the installation of a 5600 gallon ammonium hydroxide storage tank, installed in 1986 and reviewed by Baltimore Gas and Electric Company (BGE) in 1996, failed to include a written safety evaluation which provided the determination that the change did not involve an unreviewed safety question. The hazardous material dbnsequence ofa spill ofammonia as described in the December 30,1980, BGE letter to the NRC, referencedin the UpdatedFinalSafety Analysis Report Section 1.8, Subsection Ill.D.3.4, and Updated Final Safety Analysis Report (UFSAR) Figure 1-2 were revised by the installation of the tank. As a result of not completing a safety evaluation, BGE alsofailed to update thefinal j safety analysis report.

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L ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Baltimore Gas and Electric Company accepts the violation.- We agrec that Figure 1-2 of the_UFSAR should have been PM Treatment ofinfonnation incorporated by re.ference in the UFSAR is's current industry , M

- topic.' We plan to implement necently issued Nuclear!EidrgylnstitseIguidando an'thfiibpic in aoocirdance t E Wjk wiethe ubidule desribed be$ ' M MAMi~ 4IFW*lV Z* ~ W W ' ' ?- # *4 11. REASONS FOR THE VIOLATION In 1997, a modification was issued to replace the 5600 gallon ammonia tank with an 8500 gallon ammonia tank and increase the ammonia concentration. This modification addressed all technical issues (e g., chemical spills, Control Room habitability), but responsible personnel failed to notice that the tank was indicated on the site plot plan. Therefore, the need to perform a 50.59 analysis was not identified.

In addition, the fact that the tank was incorrectly identified as a morpholine tank was also not noticed and corrected.

l. in 1991, we incorporated information summarizing certain Nuclear Regulatory Commission-issued Safety Evaluation Reports such as those relating to NUREG-0737. Rese summaries included references i to the specific correspondence. Section 1.8, Subsection III.D.3.4 and its reference to BGE's 1980 letter

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l~ noted in this violation, was one case of this added material. %ese references were intended to guide future reviewers to relevant documents. It was 'not our intent that all information contained in these documents was to be considered " described in the Safety Analysis Report" when screening the subjects for 10 CFR 50.59 applicability.

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ATTACIIMENT (1)

NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-01 III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED A detailed safety evaluation has been performed to ensure that the ammonia tank does not represent an Unreviewed Safety Question, and pending changes to UFSAR Figure 1-2 have been issued. -

IV. CORRECTIVE STEPS THAT WII I, BE TAKEN TO AVOID FURTHER VIOLATIONS Over the past several years, extensive emphasis has been placed on ensuring changes to our facility are conservatively reviewed for 10 CFR 50.59 applicability. In order to ensure that design engineers are aware of the detail contained in the UFSAR Site Plan, training will be conducted concerning the details of this issue. In addition, we will conduct training of 50.59 reviewers to enhance awareness of those topics contained in Section 1.8 of the UFSAR.

Industry guidance has recently been issued by the Nuclear Energy Institute regarding 10 CFR 50.59. He Nuclear Energy Institute guidance directly addresses treatment of information incorporated by reference in the UFSAR. We plan to implement this domment by June 30,1998. In addition, a detailed review of the Calvert Cliffs UFSAR is currently in propess to identify and correct any inaccuracies. This review includes evaluating incorporation ofinformation from past NRC Safety Evaluation Reports. This review is expected to be completed by October 1998. He majority of UFSAR corrections that result from this review should be incorporated into the 1998 and 1999 revisions to the UFSAR. Rese steps will clarify our expectations for application of 10 CFR 50.59.

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V. DATE'WWFN FULL COMPLIANCE WTI.T. BE ACHIEVED.

We were in full compliance when the detailed safety evaluation was completed for the ammonia tank.

All pending changes to the UFSAR with regard to this issue have been completed. We plan to implement the Nuclear Energy Institute guidance regarding 10 CFR 50.59 by June 30,1998.

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A'ITACHMENT (2)

NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-02 B. Calvert Cli[fs Technical Specylcation 6.4.1 states that written procedures be established and implemented, covering the activities referenced in Appendix A of NRC Regulatory Guide 1.33, Revision 2, datedFebruary 1978. The regulatory guide includes in Section 6 (r), Proceduresfor Combating Emergencies and Other Sigmficant Events, including, Other Expected Transients that may be Applicable.

Contrary to the above, as of October 15,1997, BGE had neither established nor implemented a procedurefor combating a spillfrom an ammonia storage tank located within the protected area boundary. Specylcally, followihg a postulated ammonia spill, actions for combating the spill including alignment of control room ventilation, personnel response, and the need for self-contained breathing apparatus, had not been established into written procedures.

I. ADMISSION OR DENIAL OF THE ALI.FGED VIOLATION Baltimore Gas and Electric Company accepts the violation.

II. REASONS FOR THE VIOLATIQN Engineering and chemistry procedures were not adequate to ensure changes to chemhal concentrate:ns, quantities, or storage conditions within the protected area were assessed to determine if changes to emergency procedures were required. As a result, the personnel responsible for the development of emergency procedures used to respond to possible ruptures / breaks in the ammonia tank were not notified of the potential need for a chemical-specific response procedure for the new ammonia tank.

III. CORRECTIVE STEPS THAT HAVE HEEN TAKEN AND RERULTS ACHTEVED -

Revisions 20 and 21 have been processed to Emergency Response Plan Implementation Procedure 3.0, .

"Immediate Actions." These revisions changed Attachment 19, Hazardous Material Release / Spill. Steps have been added to Attachment 19 to assess Control Room habitability for the presence of ammonia or any other chemical at the onset of a hazardous material release / spill. Action is prescribed in the event a chemical odor is present. Additionally, this revision identifies the location of respiratory equipment should it be needed.

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Special training has been provided to Operations personnel on the use of self-contained breathing apparatus. This training identified the locatica of self-contained breathing appsratus and provided practical experience with self-contained breathing apparatus donning and activation. The object of this special training was to promptly re-familiarize operators in the use of self-contained breathing apparatus.

l Self-contained breathing apparatus training program will be revised. The revised program will include practical experience with self-contained breathing apparatus donning and activation on an annual basis.

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ATTACHMENT (2)

NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-02 IV. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS To avoid further violations of this nature, revisions will be made to appropriate engineering and chemistry procedures. Provision will be made to initiate an assessment of chemical spill response procedures any time analysis determines that greater than 50 percent of a chemical's toxicity level can be realized in the Control Room. The assessment will evaluate whether additional measures are needed for Control Room response to the chemical in question.

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V. DATE WHEN FULL COMPLIANCE WIIL BE _ ACHIEVED Full compliance was achieved with the revisions to Emergency Response Plan Implementation Procedure 3.0, Attachment 19.

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A'ITACHMENT (3)

NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-04 l C. Calvert Cli[fs Technical Specification 6.4.1 states that written procedures shall be established and implemented covering the activities recommended in Appendix A ofNRC Regulatory Guide 1.33, Revision 2, February 1978. Regulatoiy Guide 1.33, Section 7,(e)(4) provides for radiation protection proceduresfor contamination control. ~

Contrary to the above, as ofNovember 1,1997, BGE had neither established nor implemented a procedure that provided contamination controlfrom laundered and re-used anti-contamination  ;

clothing.

, l I. ADMISSION OR DENIAL OF TIIE AII FGED VIOLATION Baltimore Gas and Electric Company accepts the violation.

II. REASONS FOR THE VIOLATION The Radiation Safety Procedure (RSP) 2-406, Revision 2, Laundering of Contaminated Clothing, did not l describe actions to be taken by equipment operators when stated acceptance criteria were exceeded, other I than to report the results to a Radiation Safety supervisor. The procedure lacked criteria for increasing the sample size or dispositioning laundry when a high failure rate of monitored clothing was observed. l The failure rate was used to assess the laundry vendor's performance. The contamination levels detected l

on clothing failing the monitoring was not assessed to determine if a personnel hazard existed or if the l

acceptance criteria'for laundering of anti-contamination clothing (no significant skin contamination) I could be exceeded. gDuring/Aprih1997,? Radiation SafetyfTechnicians and contractor' :personnel performing Isundry monitoring in accorda'nce Wth'RSP-2-406 failed to document the high rate of failure

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of protective clothing (primarily boots of various sizes), returned from a laundry vendor. The personnel failed to elevate the issue to the appropriate level of supervision for a decision on corrective actions and the dissemination ofinformation to affected site personnel. The NRC Resident Inspector identified other dates in April, May, and August 1997, where during the monitoring of the laundry, numerous articles failed the monitoring threshold / acceptance criteria.

III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED The following immediate corrective steps were taken:

A. An issue report (IRI-041-829) was written on November I /,1997, and a procedural change

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was initiated.

B. A formal root cause analysis for this event commenced.

C. An immediate change to RSP 2-406 was implemented on November 25,1997, to

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incorporate actions that included instructions to expand the sample size of monitored articles when an acceptable failure rate is exceeded. This procedure was also revised to provide instructions related to appropriate disposition of the monitored articles. The

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procedure does not allow release of anti-contamination clothing for use in the radiological !

controlled area until monitoring is completed for the appropriate articles. l D. Awareness training was given to all Materials Processing personnel concerning the specifics of this issue. *

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ATTACIIMENT (3)

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NRC REGION I INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-04 Since the immediate change to RSP 2-406 went into effect on November 25,1997, we have had no similar events at Calvert Cliffs.

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IV. CORRECTIVE STEPS THAT WII.I. BE TAKEN TO AVOID FURTHER VIOLATIONS We are revising the appropriate procedures to incorporate an improved statistical sample determination inspection criteria and frequency. Additionally, the requirements for actions to be taken by both workers and supervisors, when acceptance crit'eria are exceeded, will be reviewed and revised throughout the Radiation Safety Procedures as part of the procedure upgrade initiative. All appropriate Radiological Protection personnel will be trained on the revised procedures. We will conduct an effectiveness review of the revised procedures, as appropriate. If additional corrective steps result from the root cause analysis, they will be implemented, as appropriate.

V. DATE WHEN FULL COMPLIANCE WIIL BE ACHIEVED Full compliance was achieved on November 25,1997, when an immediate change to RSP 2-406 was implemented.

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ATTACHMENT (4)

NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50418/97-06 VIOLATION 97-06-06 D. 10 CFR 20.1501 states that each licensee shall make or cause to be made, surveys that may be necessary to comply with the regulations in thispart, and are reasonable to evaluate the potential radiological hazard that may be present. 10 CFR 20.1204 states thatfor the purpose ofassessing dose, licensees shall take suitable measurements ofconcentrations ofradioactive materials in air in work areas.

Contrary to the above, on September 16, 1997, during seal replacement of the 11B Reactor >

Coolant Pump, the air samples were not collected in a suitable location that would be representative ofthe airborne radioactivity to which afected workers were exposed as necessary to comply with 10 CFR 20.1204 I. ADlWIRRION OR DENIAL OF THE AI.I.FGED VIOLATION '

Baltimore Gas and Electric Company accepts the violation.

II. REASONS FOR THE VIOLATION The reasons for this violation are as follows:

A. Personal Air Samplers were not used to monitor for potential air borne radioactivity as there was no clear management expectation to use these instruments.

B. 'Ihe Radiation Safety Technician, at the job site, did not use conservative decision-making :

to position the air sampler in the location where the. highestLradioactivelairbornei M y contamination could potentially be present.

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III. CORRECTIVE STEPS THAT HAVE RFEN TAKEN AND RERULTS ACHIFVED The following immediate corrective steps were taken:

A. An Issue Report was initiated on September 18, 1997, documenting the event and the immediate actions taken.

B. Affected personnel were whole body counted. The results showed that each affected worker received less than 0.1 percent of their annual limit of intake.

C. A root cause analysis of the event was commenced.

D. Radiation Safety Technicians were trained on the use of the Buck Simple Sampler Personal Air Samplers, and this instrument is being employed on designated jobs to collect breathing zone air samples. This training included clearly defined management expectations on the use of personnel air samplers.

No similar events have occurred at Calvert Cliffs since September 16,1997.

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NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-06 IV. CORRECTIVE STEPS THAT WIIL BE TAKEN TO AVOID FURTHER VIOLATIONS The following corrective steps will be taken to avoid further violations: _

A. Procedures are being revised to strengthen criteria for taking representative air samples.

B. All Radiation Safety Technicians will be trained on this event and the importance of ensuring that representative air samples are obtained.

C. We will conduct an effectiveness review of the training diset.ssed above.

If additional corrective steps result from the root cause analysis, then they will be implemented as appropriate.

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved with the completion of the training on December 16,1997.

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NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-05 E. Technical Specification 6.4.1 states that written procedures shall be established and implemented covering the cctivities recommended in Appendix A of Regulatory Guide 1.33, Revision 2.

Appendix A ofRegulatory Guide 1.33, Revision 2, &ction 7.e.(1) lists access control to radiation areas including a radiation work permit system. The Calvert Clifs Radiation Safe ~ty Manual, Revision 1, Sections 6.2.I.3.e and 6.2.1.2.6 require that each person working under a specopc special (radiation) workpermit (SWP) comply with the specifc special workpermit in all respects.

SWP No. 802, task C (remove / replace 11B Reacto- Coolant Pump [RCP] seal) specifiedfull protective clothing dress plus water resistant outer clothing, face shield, kneepads, and extra boots andgloves.

SWP No.11, task C (Inspections and minor maintenance in all areasfollowing a reactor trip)

speciped that in the absence of respiratory protection or facial anti-contamination clothing (Anti-Cs), the thermoluninescent detector be worn on the outside of the Anti-Cs, with the beta window not covered.

1. Contrary to the above, on September 16,1997 during seal replacement of the 11B RCP, a worker actively performing radiological work as authorized by SWP 802, task C, was not wearing the protective clothing as specsfed by the SWP, in that the individual did not wear

- aface shield or water resistant outer clothing though engaged in handling the RCP seal container, andspraying the seal with water to minimize airborne radioactivity.

L- ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Baltimore Gas and Electric Company accepts the violation.

IL REASONS FOR THE VIOLATION On the morning of September 16,1997, a pre-job brief was held with a team of personnel from Major Machinery, the responsible maintenance group assigned to replace the No. IIB RCP seal, Plant Engineering, and Radiation Safety.~ Thejob steps for the evolution were discussed during the brief, along with the specific radiological requirements for each task heading in the SWP to be used (SWP No. 802, !

" Removal / Replace Scal" headings A, B, and C). The dress-out requirements for each specific job step ;

were not discussed.' The Major Machinery craft were signed-in under Section C of SWP No. 802, ,

" Removal / Replace Seal." The dress requirements for this section included full Anti-Cs with water l

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l resistant outer clothing, face shield, kneepads, extra boots, and gloves. The Major Machinery Supervisor l- - was signed in under Section A of SWP No. 802, " Support Activities." The dress requirements for this section only required full Anti-Cs. The supervisor was signed in under this section throughout the entire seal replacement evolution.

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During the brief, the team discussed inow the Major Machinery craft would remove the seal, place it in the canister, and remove it from the RCP bay. The team discussed how the supervisor would be inside the pump bay stationed outside of the RCP shroud and would perform support activities such as providing oversight, procedure control, and even the handing of tools to workers inside the shroud. The ,

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team did not discuss or consider the potential for the supervisor to perform job steps that were supposed ,

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ATTACHMENT (5)

NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-05 After entering the containment, two mechanics from the Major Machinery crew went into the shroud area to pull the seal. A third mechanic was stationed outside of the shroud next to the seal canister. The supervisor was stationed outside of the shroud on the opposite side of where the canisterTvas located.

The seal was pulled and moved to a location next to the canister. Due to the heat and humidity, the first crew became fatigued and the decision was made to bring in the standby crew. The supervisor, concerned with environmental conditions and exposure from the seal, requested and received permission to perform hands-on job steps associated with removing the seal from the pump bay. This was a deviation from what was discussed at the brief(i.e., the craft was to perform all hands-on activities).

Section C of the SWP No. 802 was written to address job steps associated with removing and replacing the RCP seal, but did not clearly state this included all hands on work in the RCP bay. The work supervisor was not appropriately dressed nor signed-in under Section C when he performed hands-on work. If the potential for the supervisor to perform hands-on work had been identified prior to the start of the seal removal / replacement evolution, a decision should have been made to have the supervisor sign in under Section C of the SWP. Instead, the supervisor and the Radiation Safety Technician made the inappropriate decision in the field to allow the supervisor to perform hands-onjob steps under Section A of the SWP.

III. CORRECTIVE STEPS THAT HAVE BFFN TAKEN AND RFRULTS ACHIFVED Calvert Cliffs procedures RSP l-106 and MN-1-100 both contain guidelines for conducting prejob

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briefs. These guidelines state assigned individuals and specific roles and responsibilities should be discussed during pre-job briefs.

The Plant General Manager issued specific expectations via a site memo stating roles and responsibilities l l

for high radiation area pre-job briefs. Effective December 15,1997, a first line supervisor is expected to: j (1) attend every high radiation area pre-job brief that affects their business function; (2) actively l participate in the brief to ensure success from safety, quality, and coordination standpoints; and (3) l

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provide feedback on how the job went and whether attendance had a positive impact on improving the overall work process within the radiological controlled area. The supervisor is expected to discuss specific roles and responsibilities, survey results, as well as conditions that may require work to be stopped or necessitate the need for contingency plans. ,

IV. CORRECTIVE STEPS THAT WHL BE TAKEN TO AVOID FURTHER VIOLATIONS To ensure all personnel who perform hands-on work in the RCP bays associated with the removal and replacement of an RCP seal are adequately dressed, future RCP seal replacement SWPs will be written to clearly state the specific activities that can be performed under each section of the SWP.

Site Supervision will conduct tailgate training with workers who have access to the radiological controlled area to stress the importance of SWP adherence in the field, Additionally, we are currently conducting a root cause analysis of this event. Additional applicable ,

corrective actions will be developed and implemented as necessary.

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ATTACHMENT (5)  ;

NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-05 V. DATE WHEN FULL COMPLIANCE WILI BE ACHIEVED l Full compliance was achieved on December 15,1997 with the issuance of the Plant Generil Manager's memo. l i

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ATTACIIMENT (6)

NRC REGION 1 INTEGRATED INSPECTION REPOR r NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-07 E. Technical Specification 6.4.1 states that written procedures shall be established and implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2.

Appendix A ofRegulatory Guide 1.33 Revision 2, Section 7.e.(1) lists access control to radiation areas including a radiation work permit system. The Calvert Chffs Radiation Safety Manual, Revision 1, Sections 6.2.1.3.e and 6.2.1.2.6 require that each person working under a specific special(radiation) workpermit (SWP) comply with the specific special workpermit in all respects.

SWP No. 802, task C (remove / replace 11B Reactor Coolant Pump seal) specifiedfull protective clothing dress plus water resistant outer clothing. face shield, kneepads, and extra boots and gloves.

SWP No.11, task C (Inspections and minor maintenance in all areas following a reactor trip)

specified that in the absence of respiratory protection or facial anti-contamination clothing (Anti-Cs), the thermoluninescent detector (TLD) be worn on the outside of the Anti-Cs, with the beta window not covered.

2. Contrary to the above, on October 24,1997 during an initial containment entryfollowing a reactor trip, two radiation safety technicians performing radiological work authorized by SWP 11, task C, were not wearing either respiratoryprotection or their TLDs on the outside ofthe Anti-Cs, with the beta window not covered.

L ADMIRMION OR DENIAL OF THE ATJFGED VIOLATION Baltimore Gas and Electric Company accepts the violation.

l IL REASONS FOR THE VIOLATION

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The reasons for this violation are as follows:

A. The two Radiation Safety Technicians (RSTs) involved with this event failed to follow the requirements stated in the applicable Special Work Permit (No. 97-11), specifically, "in the absence of Respiratory Protection or Facial Anti-Cs, the thermoluminescent detector (TLD)

is to be worn on the outside of the Anti-Cs." The two RSTs did not practice the "Stop, Think, Act, and Review,"(STAR) principle and did not perform self-checking.

B. A copy of the applicable SWP (No. 97-1l) was not present at the Unit 1 Containment persoa.el air lock, as required.

III. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED The following immediate corrective steps were taken:

I A. The two affected RSTs moved their TLDs to the outside of their protective clothing, as required by SWP No. 97-11.

b. An Issue Report was initiated on October 24, 1997, documenting the event and the immediate action taken.

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ATTACliMENT (6)

NRC REGION 1 INTEGRATED INSPECTION REPORT NOS. 50-317/97-06 AND 50-318/97-06 VIOLATION 97-06-07 C. A root cause analysis of the event is complete.

No similar events have occurred at Calvert Cliffs since October 24,1997.

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IV. CORRECTIVE STEPS TIIAT WIIL BE TAKEN TO AVOID FURTHER VIOLATIONS The following corrective steps will be taken to avoid further violations:

A. Appropriate Radiation Safety personnel will be provided training on using the STAR principle.

B. Appropriate personnel action was ad ninistered.

C. Copies of SWPs will be located at the appropriate areas in the RCA.

V. DATE WHFN FULL COMPLIANCE WIII BE ACHIEVED Full compliance was achieved on October :4,1097, when the two affected RSTs moved their TLDs to the outside of their protective clothing, as required by SWP No. 97-11.

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