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Text

Insp Repts 50-317/97-08 & 50-318/97-08 on 971221-980207. Violations Noted.Major Areas Inspected:Operations,Maint, Plant Support & Results of Specialist Insps in Emergency Planning & Security
	ML20217F148
Person / Time
Site:	Calvert Cliffs, 05000319
Issue date:	03/20/1998
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20217F131	List: ML20217F125; ML20217F142; ML20217F148;
References
	50-317-97-08, 50-317-97-8, 50-318-97-08, 50-318-97-8, NUDOCS 9803310290
	Download: ML20217F148 (45)
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U.S. NUCLEAR REGULATORY COMMISSION REGION 1 License No DPR-53/DPR 69 Report No /97-08 & 50-318/97-08 Licensee: Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203

Facility: Calvert Cliffs Nuclear Power Plant Units 1 and 2 i

Location: Lusby, Maryland Dates: December 21,1997 through February 7,1998 Inspectors: J. Scott Stewart, Senior Resident inspector Fred L. Bower Ill, Resident Inspector Henry K. Lathrop, Resident inspector William Maier, Emergency Preparedness Specialist Edward King, Physical Security inspector i

Approved by: Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects i

9803310290 980320 PDR G

ADOCK 05000317 pyg i

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EXECUTIVE SUMMARY Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection Report Nos. 50-317/97-08and 50-318/97-08 This integrated inspection report includes aspects of BGE operations, maintenance, and plant support. The report covers a seven week period of resident inspection and the results of specialist inspections in emergency planning and securit Plant Operations The inspectors conducted frequent reviews of control roorn operations and observed that the control room operators were attentive and responsive to plant conditions, and knowledgeable of the status of annunciators. Safety and risk significant systems and support systems were observed to be appropriately aligned during periodic main control panel walkdowns. Control room operators demonstrated appropriate use of self-checking, peer checking, and three-way communication technique The inspectors concluded that BGE was slow to recognize that the secondary control element assembly (CEA) indication system was inoperable, the plant had operated outside technical specifications, and that this event was reportable. This was determined to be a violation of NRC requirements (VIO 50-317/97-08-02). Recent unreliability of the primary CEA indication system contributed to BGE's difficulty in determining which CEA indication system was inoperabl Two examples of BGE's failure to develop adequate test procedures to ensure the operability of the CEA secondary position indicating systems viere identified. This was also determined to be a violation of NRC requirements (VIO 50-317&318/97-08-01).

When the secondary position indicating system was replaced during the 1994 Unit 1 refueling outage, BGE's design control measures did not identify the need to change the variable power supply voltage and revise the applicable plant procedures and drawing l This was treated as a Non-Cited Violation (NCV 50-317&318/97-08-03).

The inspectors concluded that the non-licensed plant operators observed during two plant tours were experienced and knowledgeable. BGE established processes for problem identification, communications, and procedure adherence were wellimplemente Maintenance The observed maintenance was conducted safely and in accordance with BGE approved procedures and controls. Workers were knowledgeable and performed work effectivel Quality verification personnel provided effective oversight of selected maintenance job The observed surveillances were conducted safely and effectively demonstrated system operability. Thorough and detailed pre-test briefings were a strength of the surveillance testing observe J ii l

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e Executive Summary (cont'd)

Plant Suonort i

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

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. good initiative and valuable tool for identifying areas for improvement. The results of the assessment will remain unresolved pending further NRC review of the specific issues and

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corrective actions taken.

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

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conduct of fire protection activities, an effective penetration seal program, appropriate control of fire brigade qualification, effective audits for identifying problems and initiating corrective actions, and good control of combustible material Overall, the emergency preparednesss (EP) facilities, equipment, supplies and

- instrumentation were being adequately maintained. Facility inventory verifications were

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

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

The emergency planning training program implementation meets the requirements of the emergency response plan, the emergency response plan implementing procedures and the Emergency Response Training Program Manual. The qualifications of Emergency Response l Organization members were being tracked. Continuing emergency response training is l provided by the individual site departments. However, there was weak central oversight of L emergency planning training activities. Continuing training exams may cosa, a broad range

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of department specific topics and may not adequately examine knowledge of emergency planning concepts.

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

! through September 1997 (VIO 50-317&318/97-08-05). The corrective actions which j were taken prior to the inspection exit interview and which were presented in an meeting at the Region I offices on February 2,1998, were adequate in response to this violation.

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

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

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walkthroughs. They did not follow their procedure when they failed to consult with the l interim Site Emergency Coordinator to develop this assumption (VIO 50-317&318/97-08-06). The inspectors noted that this training deficiency was similar to the exercise weakness observed in NRC Inspection Report 97-09. Due to the repetitive nature of this deficiency, these examples were cited as a violation of NRC requirement Senior site management is adequately involved in and informed about Emergency Planning Unit (EPU) activities. The inspectors concluded that the two most recent Nuclear Performance Assessment Department audits met all regulatory requirements. The 1997 audit report was thorough and detailed and was more detailed than previous audit reports, f BGE's self-assessment program, with 127 self-assessments initiated in calendar year 1997, was a good initiativ iii l

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Executive Summary (cont'd)

BGE was effectively maintaining and competently administrating the security progra Alarm station operators were knowledgeable of their duties and responsibilities, and communications requirements were being performed in accordance with the NRC-approved physical security plan. Security training was being performed in accordance with the NRC-approved training and qualification T&Q pla Security equipment was being properly tested and maintained as evidenced by minimal compensatory posting. Assessment aids had good picture quality and excellent zone overlap. Detection aids were functional, affective ano met regulatory requirement The access authorization program was being implemented in accordance with regulatory requirements, and personnel and packages were being properly searched prior to granting protected area (PA) access. Interviews with Nuclear Security Officers, inspector observations, and procedural reviews determined that visitor access was being controlled and maintained as require Security audits were thorough and in-depth. Effective controls were in place for identifying, resolving, and preventing programmatic security problems. These controls ;

included an effective departmental self-assessment progra l

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l-TABLE OF CONTENTS E X EC UTIVE SU M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . il r

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

Summary of Plant Status ..... ......................................1 1. O pe r at io n s - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

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01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments (71707) ...........................1 01.2 Operability of Control Element Assembly Position Indication . . . . . 2 O2 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . 5 l 02.1 Observation of Auxiliary Operator Rounds . . . . . . . . . . . . . . . . . . 5 ll . M ainte n a nce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 l M1.1 General Comme nts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . 7

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

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F1 Control of Fire Protection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 l F1.1 Control of Combustibles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 I l F2 Status of Fire Protection Facilities and Equipment '. . . . . . . . . . . . . . . . . 8 l F2.1 Fire Suppression System Walkdown . . . . . . . . . . . . . . . . . . . . . . 8 F2.2 Fire Barrier Penetration Seals . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 i F3 Fire Protection Procedures and Documentation . . . . . . . . . . . . . . . . . . 10 l F3.1 Fire Protection Program procedure . . . . . . . . . . . . . . . . . . . . . . 10 F5 Fire Protection Staff Training and Qualification . . . . . . . . . . . . . . . . . . 11 F Fire Brigade 1 raining Records .........................11 F7 Quality Assurance in Fire Protection Activities ..................12 l F Quality Assurance Audits of Fire Protection Program . . . . . . . . . 12 l F8 Miscellaneous Fire Protection Activities . . . . . . . . . . . . . . . . . . . . . . . 13 L

F BGE Self-Assessment of Compliance with Appendix R to 10 CFR 50 ......................................13

, F8.2 (Closed) Violation 50-317&318/97-05-04, Emergency Lighting l Units ..........................................14

! P1 Conduct of EP Activities . ................................15 l P2 Status of EP Facilities, Equipment, and Resources . . . . . . . . . . . . . . . . 15 l P3 EP Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 l P5 Staff Training and Qualification in EP . . . . . . . . . . . . . . . . . . . . . . . . . 20 j- P6 EP Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . 21 i P7 Quality Assurance in EP Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 l P8 Miscellaneous EP issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 P8.1 (Closed): Unresolved item 50-317&318/96-06-04. . . . . . . . . . . 23 S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . 24 S2 Status of Security Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . 25 S3 Security cnd Safeguards Procedures and Documentation . . . . . . . . . . . 26 v

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Table of Contents (cont'd)

S4 Security and Safeguards Staff Knowledge and Performance . . . . . . . . . 26 SS Security and Safeguards Staff Training and Qualification (T&O) ......27 S6 Security Organization and Administration . . . . . . . . . . . . . . . . . . . . . . 27 l S7 Quality Assurance (QA) in Security and Safeguards Activitics . . . . . . . . 28 ;

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

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

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X2 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 X3 Management Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 ATTACHMENTS i

l Attachment 1: Partial List of Persons Contacted Inspection Procedures Used

Items Opened, Closed and Discussed List of Acronyms Used J

Attachment 2: Fire Barrier Penetration Seals Inspected and Drawings Referenced Attachment 3: Emergency Response Plan and Implementing )

l Procedures Reviewed '

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s Report Details Summarv of Plant Status Unit 1 began the inspection report period at full power. Power was reduced to approximately 97 percent on January 2 and was returned to full power on January 4 after the completion of planned moderator temperature coefficient surveillance testing. On January 13, BGE initiated a plant shutdown in accordance with technical specification (TS) 3.0.3 when the both low pressure safety injection headers were determined to be inoperable due to a cracked weld on a seismic restraint in the common discharge heade Power was reduced to 98 percent before the systems were restored to an operable statu Power was reduced to approximately 85 percent for scheduled maintenance on January 30 and was returned to full power on January 3 Unit 2 also began the inspection report period at full power. Power was briefly reduced to '

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

Unit 2 was operated at full power for the remainder of the inspection report perio I. Operations 01 Conduct of Operations 01.1 General Comments (71707)

Plant operations were conducted safely with a proper focus on nuclear safety. On January 13, during the inspection of the common low pressure safety injection (LPSI)

discharge line, engineering ' personnel identified a crack in the weld between a pipe support stanchion and the LPSI piping. Identification of this problem was not immediately communicated to Operations personnel. After notification of this problem approximately 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months later, Operations declared both LPSI headers inoperable. A unit shutdown was commenced in accordance with the requirements of TS 3.0.3. BGE removed the support with a temporary alteration at:d performed an engineering evaluation to support operabilit The plant was subsequently returned to full power. An NRC engineering inspection team was onsite during this period and reviewed this issue. The details of engineering team's review will be documented in NRC Inspection Report 50-317&318/98-8 Using inspection Procedure 71707, " Plant Operations," the inspectors conducted frequent reviews of control room operations. In general, the conduct of operations was professional and safety conscious. The control room operators were attentive and responsive to plant conditions. Control panels were periodically walked down and safety and risk significant systems and support systems were observed to be appropriately aligned. During the inspection period, control room operators were knowledgeable of the status of annunciators. Control room operators demonstrated appropriate use of self-checking, peer checking, and three-way communication technique m

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01.2 Operability of Control Element Assembly Position Indication J.nsoection Scope The inspectors reviewed the problems with the control element assembly (CEA)

position indication system Dbservations and Findinas On January.4, Unit 1 was operating at 97 percent power with the group 5 CEAs partially inserted for moderator temperature coefficient testing (MTC). During the MTC testing, a CEA motion inhibit alarm was received. The operators determined-that the pulse counting (primary) and voltage divider reed switch (secondary) CEA position indications deviated from each other by 5 to 6 inches for all the group 5 CEAs. The tertiary indication, the " full out" reed switch position indication, was not operable with the CEAs partially inserted. The operators determined that the position indicating systems did not meet the TS requirement for two of the three position indication systems to agree within 4.5 inche The operators investigated the problem and reviewed the issue with nuclear fuels and systems engineering personnel. Recently the primary position indicating i system has been unreliable. The Unit 1 CEAs have been maintained at the " full I out" position in lieu of the normal 132 inch position due to this system

- unreliability. BGE had identified computer cards that required replacement to improve the system reliability; however, this corrective action had not been completed prior to the Unit 1 MTC testing. Additionally, BGE had considered the secondary indication more accurate than the primary indication since the secondary indication determines position from reed switches spaced along the CEA housing whereas the primary indication infers position from counting pulses sent to the CEA magnetic jack mechanism. The operators concluded that the primary indication system was inoperable based on the results of their investigations, the system's accuracy and unreliability, and consultation with engineering personne The operators promptly entered TS action 3.1.3.3.b, which allows continued operation for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months with the primary position indication system and one of the remaining position indication systems inoperable. BGE personnel completed the MTC testing and proceeded to return the CEAs to the " full out" position. This action was completed, on January 5, within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time allowed by the TS action statement. The deviation between the primary and secondary position indicating systems narrowed to approximately three inches, but remained until the CEAs reached " full out" indication on the tertiary indication. The TS action statement was exited when the " full out" indication became operabl Subsequent information indicated all of the CEAs in group 5 were maintained within 7.5 inches of each other as required by technical specifications. Therefore, this event was of low safety significance since assumed values for peaking factors, power distribution and shutdown margin were not exceeded by maintaining the CEA deviation within TS limit I

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i On January 5, the inspectors observed that instrument maintenance technicians

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

secondary position indication system voltage divider. The voltage had drifted from the setting specified in a once per refuel cycle instrument maintenance procedure j for aligning the CEA position indicating system. The inspectors questioned why j troubleshooting was being performed on the secondary system when the primary '

system had previously been identified as the inoperable system. The inspectors further noted that no specific TS action existed for the previous simultaneous l inoperability of the secondary position indication and the " full out" indication. The ;

inspectors questioned whether the plant was operated outside of technical specifications since TS 3.0.3 had not been entered on January 4. BGE personnel indicated that investigations and troubleshooting were ongoin On January 6, the inspectors discussed the secondary position indication j troubleshooting plan development with system engineering and instrument j maintenance personnel. These personnelindicated that a three inch deviation would still remain if the CEAs were reinserted. For example, if the rods were l reinserted from the " full out" position of 135 inches, the secondary would not I indicate that the CEAs were moving until they were inserted below 132 inche The deviation was suspected to have resulted from incorrectly setting the voltage !

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

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BGE personnel believed that the voltage setting had been incorrect and undetected i since the system was modified in 1994 to install a new viewing screen that applied a smaller resistance to the voltage divider network. BGE personnel also !

identified that there was no periodic surveillance test of this power supply voltage I setting that was critical to the accuracy of the secondary position indicating system. BGE personnel indicated that this issue would be reviewed for generic implications. Failure to establish a test procedure to verify that the voltage divider network power supply voltage was at the acceptance limit specified by the applicable design documents is the first example of a violation of 10 CFR 50, Appendix B, Criterion XI, " Test Control" (VIO 50-317&318/97-08-01),

i Technical Specification Limiting Condition for Operation (LCO) 3.1.3.3 requires the CEA voltage divider reed switch position indication channel to be capable of j determining the absolute CEA position within 1.75 inches. With three inches of suspected deviation between the primary and secondary, the inspectors questioned whether TS LCO 3.1.3.3 was being met. Operations personnel stated that all the position indicating systems met this requirement at the " full out" position. However, the inspectors commented that the system must be able to meet the TS LCO and perform its design function throughout the full travel of the CE BGE assembled a cross section of plant operations, maintenance, and engineering personnel to discuss and finalize a troubleshooting and repair plan for the secondary CEA position indicating system. These personnel concluded that the secondary indicating system was not capable of determining CEA position within 1.75 inches and was therefore not operable. The secondary indicating system had not been operable since January 4. After declaring the secondary position l

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indicating system inoperable, BGE promptly increased the surveillance of CEA position from every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months as required by TS surveillance requirements 4.1.3.1.1,4.1.3.3.2, and 4.1.3.6 The increased surveillances were required since the deviation circuit, CEA motion inhibit, and power dependent insertion limit alarm functions were also rendered inoperable. BGE personnel also concluded that Unit 1 had been operated outside TS on January 4 when both the I secondary position indication and the " full out" indication were simultaneously inoperable. This was a violation of NRC requirements (VIO 50-317/97-08-02).

BGE personnel concluded that the deviation resulted from a combination of an incorrect setting and a drift in the setting of the voltage for the variable power f

supply to the secondary position indicating system. During the 1994 Unit 1 refueling outage (and 1995 for Unit 2), the secondary position indicating system ,

was replaced with a CEA voltage divider position indication system which has a l lower voltage resistance load. At that time, BGE's design control measures did not identify the need to change the variable power supply voltage and revise the ;

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

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

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

On January 6, BGE personnel calculated a new voltage setting for the Unit 1 variable power supply. The troubleshooting included adjusting the voltage to the i new setting and testing the secondary position indicating system to ensure that j

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the system was then accurate to within the LCO specifications. This new voltage setting was then made permanent. The troubleshooting was subsequently extended to Unit 2 to determine if a generic concern existed. The Unit 2 CEAs were located at their normal partially inserted position of 132 inches. No significant deviation between position indicating systems was observed. BGE troubleshooting determined that the variable power supply for the Unit 2 CEA position indicating system had drifted down to a value approximately equal to the new permanent voltage setting. The power supply was reset and the system was satisf actorily tested.

l Through investigation and discussion with BGE personnel, the inspectors l

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determined no surveillance test existed to verify the TS 3.1.3.3 LCO requirement for the CEA voltage divider reed switch position indication channel to be capable of determining the absolute CEA position within i 1.75 inches. BGE personnel identified that there may be additionalinstances where TS surveillance alone are not sufficient to verify that LCO requirements are met and no additional :

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

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

during the inspection period. Failure to establish a test procedure to verify that the CEA voltage divider reed switch position indication channel was capable of i determining the design acceptance limit of absolute CEA position is the second !

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

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

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The inspectors reviewed the updated final safety analysis report (UFSAR) and noted that. UFSAR figure 7-12 also indicates that the setpoint for the upper electrical limit or the " full out" position was at 136 inches. Additionally, the Operating Ir;structions specify aligning the primary CEA position indicating system to 135 inches when the CEAs are at the " full out" position. This figure was discussed with BGE personnel who stated that the " full out" position was actually located at between 135 and 135.75 inches. BGE personnel initiated an issue report to investigate and resolve these apparent conflicts. This issue is discussed further in Report Section Conclusions During CEA manipulations for MTC testing the primary and secondary CEA position indications for all the group 5 CEAs deviated from each other by more than allowed by technical specifications. The tertiary indication, the " full out" reed switch position indication, was not operable with the CEAs partially inserted. The i inspectors concluded that BGE was slow to recognize that the secondary CEA '

indication system was inoperable, the plant had operated outside technical j

specifications, and that this event was reportable. This was determined to be a violation of NRC requirements (VIO 50-317/97-08-02). Recent unreliability of the primary CEA indication system contributed to the BGE's difficulty in determining which CEA indication system was inoperabl Two examples of BGE's failure to develop adequate test procedures to ensure the operability of the CEA secondary position indicating systems were identified. The NRC inspectors identified one example. This was also determined to be a violation of NRC requirements (VIO 50-317&318/97-08-01). BGE personnel identified that the inoperability of the secondary position indicating system resulted from a combination of an incorrect setting and a drift in the setting of the voltage for the variable power supply to the secondary position indicating system. When the l secondary position indicating system was replaced during the 1994 Unit 1 refueling outage, BGE's design control measures did not identify the need to change the variable power supply voltage and revise the applicable plant procedures and drawings. This was treated as a Non-Cited Violation (NCV 50-317&318/97-08-03). However, throughout this event, all of the CEAs in group 5 were maintained within 7.5 inches of each other as required by technical i specifications. Therefore, this event was of low safety significance since assumed values for peaking factors, power distribution and shutdown margin were not exceeded by maintaining the CEA deviation within TS limit Operator Knowledge and Performance O2.1 Observation of Auxiliary Operator Rounds Inspection Scope (71707)

The inspectors observed non-licensed nuclear plant operators (NPOs) conduct tours of the Unit 1 auxiliary and turbine building Ie l

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f 6 Observations and Findinos l

The inspectors noted that the NPOs were experienced, and knowledgeable of their duties and plant equipment for the areas assigned. The NPOs identified several deficiencies during the plant tours. The control room was promptly notified of out-of-specification readings and local alarms. Three-way communication techniques were implemented. The NPOs initiated issue Reports (IR) to enter the minor deficiencies into the corrective action program. The inspectors noted that the NPOs used appropriate personal and radiation safety techniques. Applicable procedures, including " memory use" procedures were brought to the operating stations and followed step-by-step.

l Conclusions The inspectors concluded that the non-licensed plant operators observed during two plant tours were experienced and knowledgeable. BGE established processes for problem identification, communications, and procedure adherence were well implemented.

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11. Maintenance l M1 Conduct of Maintenance l

M1.1 General Comments Inspection Scoos (627_QZ)

l The inspectors reviewed maintenance activities and focused on the status of work that involved systems and components important to safety. Component f ailures or system problems that affected systems included in the BGE maintenance rule program were assessed to determine if the maintenance was effective. Also, the inspectors directly observed all or portions of the following work activities:

IR3-OO2-228 22 Component Cooling HX Outlet Gage Calibration IR3-OO3 684 2B Emergency Diesel Speed Switch Adapter Replacement M011998001 Remove SG Blowdown Piping and Hand Valve 104 l M01199800117 Replace 2" SG Blowdown Piping and Valve l MO1199800006 CEAPDS Position Indication Troubleshooting MO1199705396 Leak Repair Unit 1 HP Turbine Obseivations and Findinos l

l The inspectors found that tt e selected maintenance activities were performed safely and in accordance with approved procedures. Technicians were experienced and knowledgeable of the assigned duties. Pre-job briefings were effective in ensuring that the work was conducted in accordance with BGE work protocols and plans. The work instructions provided in the maintenance order i

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

! maintenance work order instructions were properly documented and approved.

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

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material exclusion controls were practiced. The inspectors noted that an I appropriate level of supervisory attention was given to the work. Quality l verification personnel were seen providing effective oversight for some maintenance work observed.

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l Conclusions The observed maintenance was conducted safely and in accordance with BGE

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approved procedures and controls. Workers were knowledgeable and performed work effectively. Quality verification personnel provided effective oversight of ,

selected maintenance job f l

M1.2 Routine Surveillance Observations Insoection Scooe (61726)

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

l STP-O-73D-1 Charging Pump Performance Test l STP-O-73A-1 Saltwater Pump and Check Valve Quarterly Operability Test STP-O-29-1 Monthly CEA Partial Movement Test STP-O-8 A-1 1 A EDG and 114Kv Bus Testing Findinas and Observations The pre-test briefings performed by the control room operators were detailed and thorough. Pre-test briefings included review of procedural steps, special precautions, means of communication, special test equipment, and contingency actions. As applicabic, past problems experienced during the performance of the tests were discussed. Excellent questioning attitudes were displayed during the pre-test briefs and all questions were satisfactorily resolved prior to commencing the test evolutions. The observed surveillance testing was performed safely and in accordance with approved procedures. The inspectors observed that an appropriate level of supervisory attention was given to the testing including direct observation of test steps. The test equipment used met procedure and calibration requirements. The inspectors observed that the details of the approved procedures in use were clear and technically adequate. The inspectors noted that the testing was performed by qualified personnel, and the test results satisfied the acceptance criteria.

( Conclusions The observed surveillances were conducted safely and effectively demonstrated system operability. Thorough and detailed pre-test briefings personnel have continue to be a strength of the surveillance testing observed, t

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111. Plant Support l

F1 Control of Fire Protection Activities F1.1 Control of Combustibled

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a. Inspection Scope

The inspector reviewed Section 5.2, " Controlling Transient Combustibles," of procedure SA-1-100, Rev. 4, " Fire Prevention," and observed the in-plant conditions during plant tour b. Observations and Findinas The controls in SA-1-100, Section 5.2 required no special controls of transient l combustibles in an area that are less than that amount assumed present in the Combustible Loading Analysis. Should the transient combustible loading exceed that amount, the job supervisor was responsible for obtaining guidance from the fire protection engineer (FPE), and implementing any additional measures specified by the FP During tours of the tacility, the inspector did not observe accumulations of '

l combustible materials in the plant. In addition, the gas cylinder storage cages, located outdoors, at the south-east corner of the services building, maintained i 25 feet separation between oxygen and fuel cylinder c. Conclusions The inspector determined that there was good control of combustible materials and oxidizers, and that housekeeping in the plant was excellen F2 Status of Fire Protection Facilities and Equipment F2.1 Fire Sucoression System Walkdown

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a. Inspection Scope The inspector conducted a walkdown of the Unit 2 Service Water Pump room Sprinkler System (Sprinkler System 205),in company of the Fire Protection Engineer (FPE). The inspector also reviewed Drawing No. 12261-28, Sheet 7, Rev.11, "Calvert Cliffs Nuclear Plant, Lusby, Maryland, Unit 2 - Elev. 5'-0"," the Automatic Sprinkler Corporation of America (ASCOA) design drawing, and Drawing 60714SH0003,Rev. 24, " Plant Fire Protection System, Turbine and Service Bldgs. & Intake Structure," the fire protection water system piping and instrumentation drawing (P&lD).

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1 Observations and Findinas The Unit 2 Service Water pump room was served by a wet pipe sprinkler system, with local and remote alarms. The system was designed by ASCOA based on

. hydraulic calculations. Local alarm was provided by a water driven bell. During l- the walkdown, the inspector observed that the pipiag was in good repair, and

! conformed to the design configuration. In addition, the sprinkler heads were of the l type, and in the locations and orientations, specified by the ASCOA design. _The

{: FPE pointed out to the inspector the location where a sprinkler head had been l removed after obtaining certification of the room's watertight door for a fire barrier door. This was performed to ease moving equipment into and out of the room,

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

l' Conclusions i

] Based upon the observed condition of the Unit 2 Service Water pump room i sprinkler system and a review of the design drawings, the inspector concluded that the system was in conformance with its design, and was in good condition.

F2.2 Fire Barrier Penetration Seals Inspection Scone I

The inspector, in company of the FPE, performed an inspection of fire barrier penetration seals between the Unit 2 45'switchgear room and the Unit 2 B cable chase. The specific penetrations inspected are listed in Attachment 2 to this ;

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

j determine the design of the seals which should be present. The inspector also reviewed Section 5.4, " Controlling Fire Barrier Penetrations," of procedure SA-1- ;

100, Rev. 4, " Fire Prevention." !

l Observations and Findinas i The fire barrier penetrations at Calvert Cliffs Nuclear Power Plant (CCNPP) used !

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

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

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

! with the face of the barrier, or not more then six inches from the face of the barrier. For those cases where shrinkage of the grout, or sagging of the metal l covers of the cable tray has created a gap, the gap is sealed using a nominal 3" ceramic fiber and %" of approved silicone sealant. For new installations, the space between the blockout and the penetrant may be scaled with room temperature vulcanizing (RTV) silicone foam. The need for internal conduit seals was based on the specifics of the conduit (size, cable fill, distance of termination from barrier) and where an enclosure was considered part of the conduit run, the enclosure must be so marke .

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The cable tray penetrations between the Unit 2 45' elevation switchgear room and the Unit 2 B cable chase all used ceramic fiber (kaowool) and flamastic to seal the tray interior. The inspector observed that both sides of the penetrations were sealed. Penetration 2-BARR 2B/407-TOOO2showed evidence of having been disturbed on the cable chase side. It was apparent to the inspector that the flamastic had been reapplied at one place on the face of the seal. The FPE indicated that this was a repair after installing a new cabl All the conduits inspected were appropriately plugged at the wall, or extended beyond the qualified minimum length, and the enclosures (junction boxes and condulets) were marked as part of the qualified penetration barrie Section 5.4 of procedure SA-1-100 permits temporary seals to be installed during the conduct of modification work. The opening must be packed with ceramic :

fiber, and an impairment must be processed, and compensatory actions specified by the FPE in place for the duration of the temporary sea Conclusions Based upon the observed condition of the fire barrier penetration seals, and a review of the design documents and procedural controls, the inspector concluded that the penetration seal program has been effective in maintaining the integrity of the fire barrier penetration seal F3 Fire Protection Procedures and Documentation F3.1 Fire Protection Proaram orocedure

I Inspection Scone 1 l

The inspector performed a review of procedures SA-1, Rev. 2, " Fire Protection i Program," and SA-1-100, Rev. 4, " Fire Prevention," in their entirety, to determine what administrative controls have been imposed on plant activities to control the risk of fire ; Observations and Findinos Procedure SA-1, " Fire Protection Program," provided the general requirements, and assigns responsibilities for the CCNPP fire protection program. Procedure SA-1-100, " Fire Prevention," provided all the specific guidance for the various functions - !

of the fire protection program. All facets of the program were covered in the single procedure, with specific guidance for compensatory measures when impairments were identified or planned. For planned impairments (such as !

breaching a fire wall, disabling a suppression system, bringing in transient combustibles), compensatory actions were required to be in place prior to the ,

impairment being implemente '

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11 Procedure SA-1-100 also included step by step guidance for administrative l processing of permits and impairments, and provided detailed instructions for hot

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work fire watches and compensatory measures fire watche c. Conclusions I The inspector concluded that procedure SA-1-100 provided excellent guidance for j the conduct of fire protection activities at the station. The inspector considered having all the guidance in one procedure a strength, since plant staff personnel can find the guidance for any activity affecting fire protection in the one procedur F5 Fire Protection Staff Training and Qualification ,

l F5.1 Fire Briaade Trainina Records Insoection Scope i The inspector reviewed the monthly Fire Brigade Status Reports for 1997, the l monthly Fire Brigade Reports for 1997, attendance sheets from several 1997 fire brigade training sessions, and reviewed six lesson plans for fire brigade training. In addition, the inspector discussed the training and qualification program with the

Fire Brigade Training Coordinator.

l l Observations and Findinas l

! BGE had committed to the 1975 edition of National Fire Protection Association (NFPA) Standard 27, which required monthly training for fire brigade members.

l BGE was conducting training for the fire brigade on a monthly basic. The monthly topics were presented by the fire and safety technicians (FASTS). Attendance records were entered into the computer tracking system for training. A printout was generated monthly showing the training status of each person qualified as a fire brigade member. The fire brigade training coordinator used that report to generate a monthly fire brigade report, which was a matrix showing each person's training status. Training which will expire during the month was shown in blue,

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

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used by the FASTS to check the designated fire brigade members at the beginning of each shift to ensure that their qualifications were up to dat Physical examinations were conducted annually by the medical departmen Physicals were currently conducted by physicians or physician's assistants from l Johns Hopkins University. On several occasions during the past five years, BGE l has had the physician or physician's assistant attend, and participate in, the annual

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fire school to give them a better perspective on what constitute the physical requirements for fire fighters. Physical qualification status was automatically down-loaded to the " Training Server" software which was used to generate the monthly status report.

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12 The training plans the inspector reviewed are listed in Attachment 2. Each lesson plan included discussion topics, lists of demonstration equipment needed for the lesson, and a set of questions for the student Conclusions Based on the review of the monthly fire brigade reports, the computer printouts of individuals' training status, and review of several lesson plans, the inspector concluded that the fire brigade qualification was appropriately tracked and controlled. In addition, the inspector considered the color coding of expired, and soon to expire, training on the monthly reports an excellent aid to the supervisors

- for identifying training needs, and for the FASTS to identify qualified fire brigade member F7 Quality Assurance in Fire Protection Activities F Quality Assurance Audits of Fire Protection Proaram Insoection Scooe The inspector reviewed audits of the fire protection program conducted since the last inspection, to evaluate the depth of review, and whether identified deficiencies

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were being appropriately addressed. Specific audits reviewed were:

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

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

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

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Report of Audit No. 95-1, First Quarter 1995, dated April 19,1995 Observations and Findinas BGE had included fire protection in the routine audit program performed by Nuclear Performance Assessment, rather than performing only a single audit each year.

l Experienced fire protection personnel from an outside entity were included in one of the assessments performed each year. In addition, Nuclear Performance Assessment performs a triennial review of the program, which includes an outside auditor.

! The audits found the program to be generally well implemented, with only minor findings. The triennial review performed in 1996 found an issue of some impor The review of training and qualification found a computer programming problem which affected updating the Calvert Cliffs Site Training Matrix for BGE offsite employees. BGE formed a " Focus" group to identify the cause, and extent of the problem and to work out a solution. The FPE stated that the problem did not resurface during the 1997 outag e

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.o 13 Conclusions Based on the lack of repeat findings, and the issuance of issue Reports and

- Programmatic Deficiency Reports (PDRs) for significant findings, the inspector concluded that the fire protection program audits were effective in identifying problems and initiating corrective action F8 Miscellaneous Fire Protection Activities F8.1 ' BGE Self-Assessment of Comoliance with Anoendix R to 10 CFR 50 Insoection Scope

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The inspector reviewed the report of the BGE self-assessment of compliance with Appendix R to 10 CFR 50, which was conducted during October and November l 1996, and the Appendix R/HVAC Project Plan and Scoping Document, issued in l

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August 1997. -In addition, the inspector reviewed issue Report (IR) 1-010-010, dated September 6,1996,IR1-011-955, dated September 6,1996, and Priority 3

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

i Observations and Findinas In response to escalated enforcement relating to switchgear room ventilation issues in 1996, BGE performed a self-assessment of compliance with Appendix R to 10 CFR 50. The assessment was conducted in October and November of

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1996, and was led by Nuclear Performance Assessment personnel, with technical l expertise augmentation by personnel from Engineering and Planning Management, l Inc. (EPM). The assessment focused on Appendix R, safe shutdown, fire protection regulatory framework, and key related programs. The team identified 34 specific issues for additional evaluation and correction, as appropriat Self-assessment team findings were broken down into three groups as follows:

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Group 1 Concerns - Corrective Actions Recommended These concerns consisted of issues which were regarded by the team as

potentially not in compliance with regulatory guidance, and not currently l_ active in BGE's corrective action program.

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Group ll Concerns - Actions to be Completed These concerns consisted of issues which the team considered might be not in compliance with regulatory guidance, but which were currently under

review or in the design process for correctio ,

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Group 111 Concerns - Recommendations for Improvements l These concerns were areas considered by the team to be in compliance with regulations, but where improvements to the fire protection and safe shutdown programs were warrante l l

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t 14 Pending further review of the specific issues, corrective actions already taken, and evaluation under the criteria in NRC's Enforcement Policy (NUREG-1600), the potential for a number of these issues to be not in compliance with NRC regulatory

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

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l Based upon the results of the BGE self-assessment, and the project plan for l addressing the issues raised, the inspector determined that the self-assessment was a good initiative, and valuable tool for BGE to identify areas for improvement

, in their fire protection and post-fire safe shutdown program i

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l F8.2 (Closed) Violation 50-317&318/97-05-04.Emeraency Liahtino Units Insoection Scope i The inspector reviewed NRC Integrated Inspection Report 50-317:318/97-05,and its associated Notice of Violation (NOV), BGE's response to the NOV dated l November 17,1997, discussed emergency lighting unit (ELU) history with the FPE l and the system engineer, and observed the condition of ELUs during plant tours and a walkdown of Unit 2 technical procedure AOP-9J, Rev. 3, " Safe Shutdown Due to a Severe Fire in Room 311 Unit 2 Switchgear Room 27'." Observations and Findinas ELU maintenance was not well tracked in the past at CCNPP. In 1995,the system l engineer initiated tracking and trending of the ELU corrective maintenance, to identify high failure items. Recurring failures in batteries was found, especially in high temperature and high vibration environments. Several ELU battery boxes in l the turbine buildings have been relocated to reduce vibration effects, and the main l steam isolation valve room battery boxes have been relocated to a lower temperature area outside the room. BGE has begun replacing the lead-acid

! batteries with gel-cells, which should have a better life. All future battery replacements will use gel-cell In addition, BGE has conducted " black-out" tests in most areas of the plant to evaluate the positioning and effectiveness of the emergency lights. These tests

! confirmed the adequacy of the lights to provide sufficient illumination to perform required post-fire safe shutdown tasks.

l During the field walkdown of AOP-9J, the inspector observed the condition of the emergency lights, and evaluated the aiming of the light heads. The inspector found that the paths to all the safe shutdown equipment requiring local manual operation were illuminated, and that the equipment was also illuminated. All the .

accessible lights on the routes were verified to be functioning by the FPE I depressing the test switch, and the inspector observing the illuminated area l

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15 By letter dated October 6,1997, BGE requested two specific exemptions to the requirements of Section Ill.J of Appendix R to 10 CFR 50. These exemptions relate to using the diesel generator backed security lights for exterior areas of the plant, and the use of portable lights in high radiation areas and switchgear cabinet interiors. At the time of the inspection, the request had not received final action by NR To improve the reliability of the ELUs, BGE has entered them into the maintenance rule program. At the time of the inspection, the performance criteria and goals for ELUs were under development. BGE intends to run the ELUs to failur Additional actions taken by BGE to ensure the ability of plant operators to perform post-fire safe shutdown manual actions included the purchase of helmet-mounted lamps with eight-hour battery packs. These lamps will supplement the installed battery-bacl:ed ELUs and compensate for any failures which do occur. The battery packs for the helmet-mounted lamps will be tested for eight hour discharge capability each quarte Conclusions Based on observations of the condition of the emtr,gency lighting units in the plant, discussions with the FPE, discussions with the system engineer, review of maintenance trending data, and review of the response to the notice of violation 50-317,50-318/97-05-04 regarding emergency lighting, the inspector determined that the emergency lights were in good condition, and that BGE was taking actions to improve the reliability of the ELUs and to compensate for any ELU failures which may occur. This violation is close P1 Conduct of EP Activities The inspectors reviewed the documentation for a Notification of Unusual Event (UE) that occurred on May 29,1997 to verify whether the response was in accordance with NRC regulations and BGE's emetgency response plan (ERP). The UE was declared for a small reactor coolant leak requiring the shutdown of the plant. The event was properly classified in accordance with BGE's procedure BGE made all the required notifications, including that made to the NRC operations center, within the required time periods. The inspectors concluded that BGE's response to this event was made in accordance with NRC regulations and the ER P2 Status of EP Facilities, Equipment, and Resources Inspection Scope (82701)

The inspectors toured the emergency operations facility (EOF), the emergency news center (ENC) and the farm demonstration building to ensure that these facilities were being maintained in accordance with the approved ERP and procedures. The inspectors also inspected a survey team vehicle to ensure that it was adequately supplied. The inspectors discussed habitability issues for the l

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technical support center (TSC) with the EP Director and the licensing engineering staff; and, reviewed equipment inventory and communication circuit testing surveillances to verify compliance with the ERP and NRC regulations.

a Observations and Findinas The EOF is a dedicated facility located just outside of the 10-mile emergency planning zone. The inspectors observed that the facility had all of the required equipment with only a few minor discrepancies. Two of the telephones used for notification of offsite authorities were not operating properly. BGE investigated, and corrected the proble The Emergency News Center (ENC) is not a dedicated facility. The equipment and supplies used for its operation are kept in carts in a locked closet. There were only minor discrepancies in the supplies listed on the checklists for the ENC. The equipment checklists were posted on the carts, but these posted checklists were not the current revision. BGE removed the outdated checklists. The inspectors did not identify any deficiencies at the farm demonstration building, where responders entering the site under adverse radiological conditions would be staged and outfitted in protective clothing and respiratory protectio The TSC is located above the control room and is part of the control room ventilation envelope. Because of design inadequacies of the control room ventilation system, which have already been documented in an NRC Letter dated August 28,1997, BGE provides for self-contained breathing apparatus (SCBA)

usage by the control room staff in the event of a serious loss of coolant acciden BGE also credits the use of potassium iodide (Kl) tablets for blocking the uptake of radioactive iodine in the event of an iodine release following an acciden There are adequate SCBAs for use by all control room personnel and all are qualified and trained in the use of SCBAs. There are not adequate SCBAs for the TSC responders who would be recalled following an accident. Nor are all TSC responders qualified for SCBA use. BGE takes credit for Kl blocking of radioactive iodine for the majority of TSC responders. BGE has not, however, determined if all TSC responders are able to either wear a SCBA or ingest Kl tablets (i.e., they are not allergic to iodine). Based on the inspectors' concerns, BGE has initiated a survey to determine which TSC responders are unable to take either of the above protective actions. BGE also initiated an issue report to document this problem and initiate corrective actio A survey team vehicle was inspected and had all of the supplies required. The vehicle was operationally ready except for a dead battery. The inspectors expressed concern over the ability of the teams to rapidly mobilize with a vehicle in such a condition. BGE replaced the battery and the inspectors verified that the vehicle was operational the next day. The inspectors reviewed the records for facility inventories. All facility inventories except one are completed by a technician in BGE's emergency planning unit (EPU). Inventories are completed l

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quarterly and following equipment use. The inspectors noted no significant discrepancie The EPU turned over responsibility for communication circuit testing to the Telecommunications Department (TCD) it. September 1996. The TCD conducted I tests of the circuits quarterly, despite the fact that NRC regulations require monthly testing of communication links to the NRC and to the contiguous State and local governments. The TCD had tested these circuits quarterly instead of monthly from September 1996 through September 1997. BGE's audit 97-10, of the emergency planning (EP) program, identified the failure to perform monthly tests of the communication circuits used to communicate with the NRC. This audit was performed in September 1997 and an issue report (IR) was written to document this fact. BGE responded to the IR, performed corrective action and closed it ou The inspectors noted that the communication circuits used to communicate with State cnd local governments had not been tested monthly during the same interval (September 1996 through September 1997). Monthly tests were being conducted from September 1997 through December 1997. Discussions with TCD : staff revealed that BGE was unaware that these circuits required the same monthly testing as the NRC communication links. These circuits were tested monthly during October to December 1997 due to workups and/or troubleshooting for the biennial exercise of November 1997. Further discussions with the EP Director revealed that BGE's self assessment of the problems noted in an issue report were ongoing, despite the closure of IR; i.e., the EPU was planning to investigate the regulatory compliance of all communication circuit testin In a February 2,1998, meeting between BGE and NRC Region I management, the EP Director presented BGE's actions taken for correction of the communications circuit testing problems described above. These actions were: (1) the reinstatement of monthly testing requirements for the circuits ia question, (2) the resumption of tracking the communication surveillances by the EPU, and (3) the addition of a step to the EPU task tracking schedule to evaluate changes to that schedule for potential decreases of effectiveness of the emergency pla Additional details concerning this meeting are documented in report section X c. Conclusions l Overall, the inspectors concluded that the EP facilities, equipment, supplies and instrumentation were being adequately maintained despite the deficiencies note These facilities, equipment, and supplies would be able to perform their intended functions in the event of a radiological acciden j The inspectors considered BGE's failure to screen TSC responders for Kl sensitivity to be an oversight worthy of corrective action. They noted that BGE was aggressively pursuing this corrective action by the initiation of the IR and the responder questionnaire. The inspectors are tracking this item as an inspector l follow-up item to assess BGE's corrective actions to ensure protection of TSC i

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responders while the control room ventilation system is still degraded. (IFl 50-317&318/97-08-04)

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

inspectors concluded that the failure to do monthly communication circuit testing with the NRC, and State and local governments, from September 1996 through September 1997, was a violation of NRC requirements (VIO 50-317&318/97-08-05). Despite the fact that BGE self-identified their failure to perform adequate testing of circuits for communication with the NRC, the corrective actions taken by BGE were not effective in identifying the failure to perform communication circuit testing with State and local governments for four months after the initial identification of the violation.

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I The inspectors reviewed BGE's corrective actions which were taken prior to the inspection exit interview and which were presented in the February 2,1998 meeting, and considered them to be adequate in response to the violation.

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P3 EP Procedures and Documentation a. Insosction Scope (82701)

The inspectors reviewed recent changes BGE made to its ERP and the Emergency Response Plan implementing Procedures (ERPIPs). The inspectors performed this review in the NRC reDional office to verify that BGE's changes to these documents were made in accordance with 550.54(q) of NRC regulations; i.e., that the changes did not reduce the effectiveness of the approved ERP and the ERP, as changed, continued to meet the requirements of $50.47(b) and Appendix E to Part 50 of NRC regulations. A list of the specific ERP and ERPIP changes reviewed i is included as Attachment 3 to this report. The inspectors reviewed the 50.54(q)

l evaluations performed for selected changes during the onsite inspectio b. Observations and Findinos l l Based upon BGE's determination that the changes did not decrease the overall effectiveness of the ERP and after limited review of the changes, the inspectors l determined that no NRC approval was required, in accordance with l 10 CFR 50.54(q).

l BGE's 50.54(q) evaluations were adequately written to address the elements of l emergency preparedness that would indicate potential decrease of effectiveness of the emergency pla c. Conclusions The inspectors concluded that BGE's changes to the ERP and ERPIPs listed in Attachmant 3 and reviewed onsite were made in accordance with 650.54(q) of NRC regulation _

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P4 Staff Knowledge and Performance in EP a. Inspection Scooe (82701)

l The inspectors conducted tabletop walkthroughs with two on-shift chemistry technicians who perform interim radiological assessment until the activation of the offsite dose assessment staff. Each technician was given two scenarios involving hypothetical gaseous releases of radioactive material offsite. These scenarios were conducted in the simulated control room under static conditions. The technicians were evaluated to determine if they were able to gather information for use in generation of accurate offsite dose consequence assessment *

b. Findinas and Observations Both technicians demonstrated familiarity with the location and reading of the radiation monitor displays in the simulated control room. They both knew where the computer for the automated dose assessment model was located and knew how to start up the automated dose assessment program. Both technicians assumed an incorrect isotopic concentration for their first scenario. They assumed ,

an isotopic breakdown based on reactor coolant activity instead of gap activity, as j would be required based on the radiation monitors' indications. This error yielded non-conservatively low dose projections compared to the intended values for the scenario Step 1.E in the procedure the technicians were using, ERPlP 107 (Interim Radiological Assassment), requires the technician to obtain concurrence of the interim Site Emergency Coordinator (SEC) on the type of accident to select for the dose projection. Neither technician performed this step properl This error in choosing the wrong isotopic assumptions in calculating the offsite doses is similar to that noted '. iring the last full participation emergency preparedness exercise, held on November 18,1997, (NRC Inspection Report 50-317&318/97-09). In that exercise, the NRC assessed the EOF staff's failure to j use the proper isotopic mix as a causal factor in their inability to effectively use the '

computer-based dose assessment model to give reliable offsite dose projection The NRC classified this issue as an exercise weakness, requiring corrective actio ]

i c. . Conclusions ;

The inspectors concluded the technicians were adequately trained in most of their i duties as interim radiological assessment personnel. They were not adequately trained to implement the procedure to obtain the concurrence of the SEC. Nor were they trained adequately to qualitatively interpret the significance of the i radiation monitor readings as far as the level of core damage they were indicatin This training deficiency raised concern on the part of the inspectors as to the effectiveness of BGE's training of the on-shift dose assessment staffs to be able to provide consistently accurate dose projections. This deficiency is a violation of NRC requirements (WO 50-317&318/97-08-06).

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P5 Staff Training and Qualification in EP ,

I a. Insoection Scone (82701)

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The inspectors interviewed EP and security training administrators to determine the level of oversight of the training program for emergency responders. The inspectors also reviewed the ERP, the EP. PIP describing EP training administration (ERPIP 904), the Emergency Response Training Program Manual (ERTPM) and l continuing training examinations for selected members of the emergency response organization (ERO).

b. Observations and Findinas (

The EP training program is administered in accordance with the ERP, ERPIP 904 y and the ERTPM. The EP Director and the EP training coordinator, who works in the Technical Training Unit, coordinate closely to oversee the program of providing training and tracking the qualifications of ERO member The responsibilities for conduct of EP training rest with several Groups, including emergency planning, technical training unit staff, general orientation training staff, operations training, the safety and fire protection unit, the security training and ;

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

coordinator is a central coordinating point for these groups and maintains many of the EP training records in a central location. A certain amount of records, most notably lesson plans and examinations for some continuing EP training are maintained by the individual organizations. Additionally, training for the responders at the ENC is not within the scope of the ERP, and the EP training coordinator does not review or comment on its quality or effectivenes Through their discussions with the EP and security training coordinators, the inspectors learned that certain groups evaluate their students' knowledge of EP ;

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

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l example, a small percentage of the questions on the annual requalification examinations for security guards cover EP concepts. These EP questions are not separately analyzed to evaluate a guard's knowledge of his or her EP dutie Therefore, it is possible for a guard to miss all the EP questions on an exam and still pass. That guard's lack of EP knowledge would go undetected. The

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inspectors learned that the same situation existed with the basic emergency

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

inspectors discussed this issue with the training staff and the EP Director. BGE l Indicated plans to review, and modify if necessary, their method of examination to evaluate if conditions like the ones described above could occu The inspectors also learned that there is only one generic lesson plan for all EP training administered by the EP training coordinator. All students are trained to the ERPIP they follow in performiag their emergency response duties, because the essential tasks the students perform are all described in the procedures. Under this arrangement, students are tested on their knowledge of procedures, but the

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l l test questions are based on explicit procedural references and the procedures are l provided when the tests are administered. In such a situation, the students are l tested on their ability to look up answers to the questions in the procedures.

l . The inspectors interviewed the EPU clerk who is tasked with ERO roster maintenance to determine the level of oversight of ERO member qualification The inspectors learned that the ERO qualification records are maintained in an l electronic data base that is sortable to identify impending or recent qualification l lapses. The inspectors' review of the ERO roster did not reveal any serious shortages of responders.

! Conclusions l

The inspectors concluded that the EP training program meets the requirements of the ERP, the ERPIPs and the ERTPM. The inspectors further concluded that the qualifications of ERO members were being closely tracked. However, there was week central oversight of EP training activities. The inspectors consider the fact that EP continuing training is " hidden" in overall requalification training for some groups to warrant increased attention by the EP Director to ensure that the EP training is being properly administered to, and evaluated for, these groups. The inspectors considered the method of training to the ERPIPs to be valid, assuming the ERPIPs contain all the tasks that responders will perform. However, the inspectors consider the method of testing this training, with ERPIPs provided to the examinees, not to be a good indicator of the trainees' knowledge of concepts.

! P6 EP Organization and Administration l Insoection Scope (82701)

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

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

the administration of the EP organization at the site. The inspectors also l interviewed the EP Director to discuss recent changes to the EPU staff and activitie Observations and Findinas The Manager-Nuclear Site Support Services and the Vice President-Nuclear Energy i were knowledgeable of the activities of the EPU. They were aware of recent

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l changes at the site in the area of EP. They were conscious of the position of their organization relative to the industry in the area of staffing. They held regular meetings with the EP Directo The EPU was decreased by one position as of the beginning of calendar year 1998. An EP technician left the unit. The technician was utilized in a less-than-full-time capacity while with the EPU, spending a significant amount of time on loan for outage management tasks. The EP Director does not plan to fill this vacancy, but rather intends to use his available staff, two of which spend

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! significant fractions of their tirne working for offsite state agencies. The EP l Director plans to use these persons for a greater percentage of the time to handle l the additional work, relying on the other nuclear utility with radiological emergency l

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preparedness obligations to the State of Maryland to assume a greater share of the work for the State. The EP Director stated that this re-alignment of tasks has been agreed to by all parties concerne c. Conclusions Senior site management was adequately involved in and informed about EPU activities. The EP Director had evaluated the reduction in his staff and

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

! reduction of emergency response capability is likely to occur from the recent changes in the EPU organizatio P7 Quality Assurance in EP Activities

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a. Inspection Scope (82701)

The inspectors reviewed reports of the last two annual EP audits - (Audits 96-17 and 97-10) conducted by the Nuclear Performance Assessment Department (NPAD) and interviewed the lead auditors for these reports. The inspectors also 3

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reviewed the EPU's self-assessment program and discussed the self-assessment effort with the EP Director, b. Observations and Findinas The two audit reports that the inspectors reviewed, as well as the two audit plans used in their formulation, were very different in their level of detail. Audit report 97-10 was much more comprehensive than audit report 96-17, which was completed the previous year. The auditors explained the recent adoption of a j

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Master Assessment Plan (MAP) by the Nuclear Performance Assessment j l Department (NPAD) as the reason for the change in methodology and level of l detail. This program established a more uniform method of program audits, using i standardized checklists to audit such attributes as organization and administration, I l and self-assessments. Both audit reports met all the requirements of 650.54(t) of j

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NRC regulations, including the evaluation of licensee interface with offsite agencies. Audit report 97-10 generated seven issue reports. The audit also identified an example of licensee non-compliance with NRC regulations regarding l

testing of communication circuits for NRC notification. The inspectors'

assessment of this finding was documented in report section P The EPU was extensively involved in self-assessment during the past year. They performed 127 formal self-assessments that resulted in fourteen issue report One of these self-assessments was for the licensee-identified failure to test communication circuits used to notify the NRC within the required frequency. This self-assessment was still ongoing at the time of the NRC inspection, and had not

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yet identified the fact that the circuit used to notify state and local agencies was similarly affected, Conclusions The inspectors concluded that the NPAD audits met all regulatory requirement They considered the 97-10 audit report, written after the implementation of the Master Assessment Plan, to be a substantial improvement over the 96-17 audit report in both methodology and scope. The inspectors concluded that BGE's self- I assessment program, with 127 self-assessments initiated in calendar year 1997, *

was a good initiativ P8 Miscelianeous EP issues P8.1 (Closed): Unresolved Item 50-317&318/96-06-04 q Inspectors conducting the last EP program inspection in 1996 opened this item because BGE had self-identified a deviation from its UFSAR and had not taken corrective action to resolve the deviation. The UFSAR described the emergency radios onsite as having digital voice protection, but BGE had removed this feature to improve reception quality. BGE revised its ERPIP for making changes to the EP program to include a review of proposed changes against the UFSAR, but failed to correct the identified deviation. This item was classified as an unresolved ite The inspectors performing this inspection verified that BGE had removed the reference to the digital voice protection from the UFSAR. The inspectors reviewed BGE's evaluations of the change both to the EP program and the UFSAR as required in 150.54(q) and $50.59 of NRC regulations.

l The inspectors also reviewed BGE's ERPIP 900, which governs BGE's preparation and control of the ERP and ERPlPs. The inspectors noted that the step for checking the change against the UFSAR had been removed from this procedure but that the requirement to review the UFSAR had been retained by reference to procedure EN-1-102, Safety Evaluation Screenings and Safety Evaluations, in Step 5.3.E.1 of ERPlP 90 Based on their review of the above items, the inspectors concludea that BGE had failed to update the UFSAR in a timely fashion for a change affecting the UFSA BGE had also completed all corrective actions to remedy the problem and prevent i recurrence of the problem. This failure constitutes a violation of minor significance and is being treated as a Non-Cited Violation, consistent with Section IV nf the NRC Enforcement Policy (NCV 50-317&318/97-08-07).

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S1 Conduct of Security and Safeguards Activities i Insoection Scope (81700)

I Determine whether the conduct of security and safeguards activities met BGE's commitments in the NRC-approved physical security plan (Plan) and NRC l regulatory requirements. Areas inspected included: access authorization program; alarm stations; communications; protected area access control of personnel and package b. Observations and Findinas Access Authorization Proaram. The inspectors reviewed implementation of the Access Authorization (AA) program to verify implementation was in accordance ;

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

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included an evaluation of the effectiveness of the AA procedures, as implemented, and an examination of AA records for 10 individuals. Records reviewed included both persons who had been granted and had been denied access. The AA program, as implemented, provided assurance that persons granted unescorted access did not constitute an unreasonable risk to the health and safety of the public. Additionally, the inspectors verified by reviewing access denial records and i applicable procedures, that appropriate actions were taken when individuals were i denied access or had their access terminated which included a formalized process that allowed the individuals the right to appeal BGE's decisio Alarm Stations. The inspectors observed operations of the Central Alarm Station (CAS) and the Secondary Alarm Station (SAS) and verified that the alarm stations were equipped with appropriate alarms, surveillance and communications L capabilities. Interviews with the alarm station operators found them knowledgeable of their duties and responsibilities. The inspectors also verified, l through observations and interviews, that the alarm stations were continuously l manned, independent and diverse so that no single act could remove the plants capability for detecting a threat and calling for assistance, and the alarm stations did not contain any operational activities that could interfere with the execution of the detection, assessment and response furction l Communications. The inspectors verified, by document reviews and discussions with alarm station operators, that the alarm stations were capable of maintaining continuous intercommunications, and communications with each nuclear security officer (NSO) on duty, and were exercising communication methods with the local law enforcement agencies as committed to in the Pla Protected Area (PA) Access Control of Personnel and Hand-Carried Packaaes. On February 4 and 5,1998, the inspectors observed personnel and package search activities at the personnel access portal. The inspectors determined, by observations, that positive controls were in place to ensure only authorized l

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l BGE was conducting its security and safeguards activities in a manner that protected public health and safety and that this portion of the program, as

' implemented, met BGE's commitments and NRC requirement Status of Security Facilities and Equipment insoection Scone (81700)

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Areas inspected were: Testing, maintenance and compensatory measures; PA y assessment aids; PA detection aids and personnel search equipmen ! Observations and Findinas Testina. Maintenance and Comnensatory Measures. The inspectors reviewed testing and maintenance records for security-relatea equipment and found that i documentation was on file to demonstrate that BGE was testing and maintaining systems and equipment as committed to in the Plan. A priority status was being assigned to each maintenance request and repairs were normally being completed

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within the same day a maintenance request necessitating compensatory measures l was generated. The inspectors reviewed security event logs and maintenance l work requests generated over the past six months. These records indicated that the need for establishing compensatory measures due to equipment failures was minimal and when implemented, the compensatory measures did not reduce the effectiveness of the security systems as they existed prior to the failure.

l Additionally, BGE is in the process of developing and implementing an automated tracking system for security equipment maintenance request Assessment Aids. On February 3,1998, the inspectors evaluated the effectiveness of the assessment aids, by observing on closed circuit television (CCTV), a NSO conducting a walkdown of the PA. The assessment aids had good picture quality and excellent zone overlap. Additionally, to ensure the Plan commitments are satisfied, BGE has procedures in place requiring the l implementation of compensatory measures in the event the alarm station operator is unable to properly assess the cause of an alar PA Detection Aids. On February 3,1998, the inspectors observed testing of all )

the intrusion detection systems in the plant protected area and the independent i spent fuel storage installation (ISFSI) and determined they were functional and effective, and met the requirements of the Pla Personnel and Packsae Search Eauioment. The inspectors observed both the routine use and the daily performance testing of BGE's personnel and package search equipment. The inspectors determined, by observations and procedural l

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! procedures and Plan commitment c. Conclusions t

BGE's security facilities and equipment were determined to be well maintained and reliable and were able to meet BGE's commitments and NRC requirements.

l S3 Security and Safeguards Procedures and Documentation a. Insoection Scope (81700)

Areas inspected were implementing procedures and security event log l b. Observations and Findinas Security Proaram Procedures. The inspectors verified that the procedures were consistent with the Plan commitments, and were properly implemented. The verification was accomplished by reviewing selected implementing procedures associated with PA access control of personnel, testing and maintenance of q personnel search equipment and visitor processin Security Event Loos. The inspectors reviewed the Security Event Log for the previous eight months. Based on this review, and discussion with security _

management, it was determined that BGE appropriately analyzed, tracked, resolved and documented safeguards events that BGE determined did not require a report to the NRC within 1 hou i

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c. Conclusions i Security and lateguards precedures and documentation were being properly implemented. Eved ! ngs v sre being properly maintained and effectively used to l analyze, track, cnd resolve safeguards event S4 Security and Safeguards Staff Knowledge and Performance a. Inspection Scope (8170G)

Area inspected was security staff requisite knowledge, b. Observations arlifindinas Security Force Reauisite Knowledae. The inspectors observed a number of NSO's in the performance of their routine duties. These observations included alarm station operations, personnel and package searches, visitor processing and requalification range instruction. Additionally, the inspectors interviewed NSOs and based on the responses to the inspector's questioning, determined that the l

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NSOs were knowledgeable of their responsibilities and duties, and could effectively carry out their assignment c. Conclusions The NSOs adequately demonstrated that they have the requisite knowledge necessary to effectively implement the duties and responsibilities associated with their positio S5 Security and Safeguards Staff Training and Qualification (T&Q)

a. Iriggection Scoce (81700)

Areas inspected were security training and qualifications, and training record b. Observations and Findinas Security Trainina and Qualifications. On February 4,1998, the inspectors randomly selected and reviewed T&Q records of 14 NSOs. Physical and requalification records were inspected for armed, unarmed, and supervisory personnel. The results of the review indicated that the security force was being trained in accordance with the approved T&Q plan. Additionally, the inspectors observed requalification range instruction, performed by the training staff. The training included a demonstration of the penetration capabilities of ammunition and the significance of selecting proper cover in the event of a weapons engagemen The instructors were knowledgeable of the course material and presented it in an effective manne Trainina Records. The inspectors was able to verify, by reviewing training records, that the records were properly maintained, accurate and reflected the current qualifications of the NSO c. Conclusigna Security force personnel were being trained in accordance with the requirements of the Plan. Training documentation was properly maintained and accurate and the training provided by the training staff was effectiv S8 Security Crganization and Administration a. Inspection Scoce (81700)

Areas inspected were management support, effectiveness and staffing levels.

I b. Observations and Findinas Manacement Sucoort. The inspectors reviewed various program enhancements made since the last program inspection, which was conducted in June 1997, l

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d t 28 These enhancements included the procurement of cellular phone capability in the l security vehicles for enhanced communication capability and the security screening database system was updated to improve efficiency and reduce the potential for human erro l Manaaement Effectiveness. The inspectors reviewed the management organizational structure and reporting chain. The Director-Nuclear Security's position in the organizational structure provides a means for making senior l management aware of programmatic needs. Senior management's positive l response to requests for equipment, training and resources, in general, has contributed to the effective administration of the security progra Staffina Levels. The inspectors verified that the total number of trained NSOs )

immediately available on shift meets the requirements specified in the Pla .

c. Conclusions. The level of management support was adequate to ensure effective implementation of the security program, and was evidenced by adequate staffing levels and the allocations of resources to support programmatic need S7 Quality Assurance (QA) in Security and Safeguards Activities 5 i

a. Insoection Scope (81700) l Areas inspected were audits, problem analyses, corrective actions and effectiveness of management controls, b. Observations and Findinas Audits. The inspectors reviewed the 1997 QA audit of the security program, conducted August 18 through September 23,1997,(Audit No. 97-13) and the 1 1997 QA audit of the fitness-for-duty (FFD) program, conducted April 16 through !

May 21,1997,(Audit No. 97-06). The audits were found to have been conducted in accordance with the Plan and FFD rule. To enhance the effectiveness of the i audits, both audit teams included an independent technical specialis The security audit report identified one finding and four recommendations. The {

finding was associated with security equipment not being listed on the currunt Controlled Materials List. The FFD audit identified one finding and three recommendations. The FFD finding was associated with employees exceeding !

overtime limits and the potential for fatigue to impac1 an individual's fitness-for- !

duty. The inspectors determined that the findings were not indicative of j programmatic weaknesses, and the findings would enhance program effectivenes j l Inspector discussions with security management and FFD staff revealed that the l l responses to the findings were completed, and the corrective actions were l effective.

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! 29 Problem Analyses. The inspectors reviewed data derived from the security department's self-assessment program. Potential weaknesses were being properly identified, tracked, and trende Corrective Actions. The inspectors reviewed corrective actions implemented by BGE in response to the QA audit and self-assessment programs. The corrective actions were effective, evidence by a reduction in personnel performance issues and loggable safeguards event Effectiveness of Manaaement Controls. The inspectors observod t' at BGE has programs in place for identifying, analyzing and resolving problems. They include the performance of annual QA audits, a departmental self-assessment program and the use of industry data such as violations of regulatory requirements identified by {

I the NRC at other facilities, as a trigger for performing a self assessmen c. Conclusions The review of BGE's Audit program indicated that the audits were comprehensive in scope and depth, that the audit findings were reported to the appropriate level of management, and that the program was being properly administered. In addition, a review of the documentation applicable to the self-assessment program indicated that the program was effectively implemented to identify and resolve l potential weaknesse V. Manacement Meetinas X1 Review of UFSAR Commitments While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected. Since the UFSAR does not specifically include security program requirements, the inspectors compared licenses activities to the NRC-approved physical security plan, which is the applicable document. While performing the inspection discussed in this report, the inspectors reviewed Section 5.5(D) of the Plan, titled " Visitor Access". The inspectors determined, by interviews with Nuclear Security Officers (NSOs),

observations, and procedural reviews, that visitor access was being controlled and maintained as required in the Pla The following inconsistency was noted between the UFSAR and the plant practices, procedures and/or parameters observed by the inspectors. As described in Report Section 01.2, UFSAR figure 7-12 also indicates that the setpoint for the upper electrical limit or the " full out" position was at 136 inches. Additionally, the Operating Instructions specify aligning the primary CEA position indicating system to 135 inches when the CEAs are at the " full out" position. This figure was discussed with BGE personnel who stated that the " full out" position was actually located at between 135 and 135.75 inches. BGE personnel initiated an issue report to investigate and resolve these apparent conflicts. BGE has an UFSAR

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Review Project in progress. Enforcement action regarding design issues identified during the BGE review have been Unresolved (URI 50-317&318/96-10-03)pending completion of the BGE initiative and NRC inspection of the completed revie X2 Exit Meeting Summary During this inspection, periodic meetings were held with station management to discuss inspection observations and findings. On March 9,1998, an exit meeting was held to summarize the conclusions of the inspection. BGE management in attendance acknowledged the findings presente I X3 Management Meeting Summary On February 2,1998, BGE's Manager of Nuclear Site Support Services, the Site Security Manager and the EP Director met with inspectors and the Chief of the Emergency Preparedness and Safeguards Branch of the Division of Reactor Safety at the NRC Region I office. This meeting was scheduled to introduce licensee plant support area management to the Region i Branch CLf. At the end of the meeting, the EP Director presented additional corrective actions taken in response to NRC-identified violation 97-08-05 that deals with communication circuit testin l l

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_ ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED Bf1E

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C. Cruse, Vice President- Nuclear Energy Division P. Katz, Plant General Manager P. Spina, Acting Superintendent, Nuclear Maintenance K. Neitmann, Superintendent, Nuclear Operations T. Pritchett, Acting Manager, Nuclear Engineering ,

S. Sanders, General Supervisor, Radiation Safety I T. Sydnor, General Supervisor, Plant Engineering I J. Lemons, Manager Nuclear Support Services Department A. Edwards, Director Nuclear Security J. Holleman, Fitness-for-Duty Administrator

. J. Alvey, Supervisor Security Training and Support

! M. Burrell, Supervisor Security Screening, Training and Support J. Frost, Nuclear Security Supervisor D. Dean, Security Program Specialist P. Hines, Security Training Specialist ;

T. Roxey, Senior Engineer Nuclear Regulatory Matters C. Sly Senior Engineer (

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T. Forgette, Director- Emergency Planning l J. Hardison, Emergency Response Training Coordinator J. Osborne, Nuclear Regulatory Analyst J. Phifer, Senior Assessor- Nuclear Performance Assessment Department P. Pringle, Emergency Planning Analyst

! W. Ramstedt, Assessor- Nuclear Performance Assessment Department l M. Tonacci, General Supervisor- Chemistry i

C. Sinopoli, Appendix R & Fire Protection Engineer l J. Wood, Fire Protection Design Engineer l L. Williams, Emergency Lighting System Engineer l D. Buffington, Fire Protection System Engineer L. Nuse, Fire Protection Specialist l W. Hale, Senior Technical Instructor G. Cooper, Sr. Electrical Engineer E. Mc Cann, Electrical Engineer N_!1C

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l A. Dromerick, Project Manager, NRR T. Hoeg, Reactor Engineer F. Laughlin, Resident inspector- Salem G. Meyer, Chief, Civil, Mechanical, and Materials Engineering Branch, DRS L. Nicholson, Deputy Director, Division of Reactor Safety J. Wiggins, Director, Division of Reactor Safety K. Kolaczyk, Operations Engineer

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Attachment 1 2

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INSPECTION PROCEDURES USED IP 61726: Surveillance Observations IP 62707: Maintenance Observation IP 71707: Plant Operations IP 82701: Operational Status of the Emergency Preparedness Program i IP 92904: Followup - Plant Support IP 81700: Physical Security Program for Power Reactors l lP 64704: Fire Protection Program

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IP 64150: Triennial Postfire Safe Shutdown Capability Reverification L ITEMS OPENED, CLOSED AND DISCUSSED Opened l

50-317,318/97-08-01 VIO Failure to establish adequate test procedures for the secondary CEA position indicating system 50-317/97-08-02 VIO Failure to meet TS 3.1.3.3 when two CEA position indications systems were inoperable l 50-317,318/97-08-03 NCV inadequate design contrcl of variable power supply voltage settings 50-317,318/97-08-04 IFl Follow up on licensee actions to identify and protect TSC responders from thyroid exposure during accidents 50-317,318/97-08-05 VIO Failure to test communicatica circuits in accordance with Part 50, appendix E, par. IV. ,318/97-08-06 VIO Training deficiencies in on-shift dose assessment staff use of automated dose assessment model 50-317,318/97-08-07 NCV Survey team radios not compliant with UFSAR (URI)

50-317,318/97-08-08 URI Potential for issues identified during Appendix R self assessment to be not in compliance with regulatory requirement Closed l 50-317,318/96-06-04 URI Survey team radios not compliant with UFSAR (NCV)

f 50-317,318/97-08-03 NCV inadequate design control of variable power supply voltage settings

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' Attachment 1 3 50-317,318/97-08-07 NCV Survey team radios not compliant with UFSAR Discussed 50-317,318/96-10-03 URI Old design issues identified during the BGE UFSAR review l'

LIST OF ACRONYMS USED AA Access Authority ASCOA Automatic Sprinkler Corporation of America BGE Baltimore Gas and Electric CAS Central Alarm System CCNPP Calvert Cliffs Nuclear Power Plant

! CCTV Closed Circuit Television i CDA Containment Dose Assessment CEA Control Element Assembly CFR Code of Federal Regulations CR/TSC Control Room / Technical Support Center l ELU Emergency Lighting Unit EOF Emergency Operations Facility l ENC Emergency News Center

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EPZ Emergency Planning Zone ERO Emergency Response Organization ERP Emergency Response Plan ERPIP Emergency Response Plan implementing Procedure ERTPM Emergency Response Training Program Manual FAST Fire and Safety Technician FFD Fitness For Duty FPE Fire Protection Engineer HX Heat Exchanger IFl Inspector Follow-Up Item IR issue Report ISFSI Independent Spent Fuel Storage Installation Kl Potassium lodide LCO Limiting Condition for Operation LPSI Lower Pressure Safety injection l MAP Master Assessment Plan l MTC Moderator Temperature Coefficient l NCV Non-Cited Violation

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NEF Nuclear Energy Facility NFPA National Fire Protection Association NOV Notice of Violation NPAD Nuclear Performance Assessment Department NPO Nuclear Plant Operations NRC United States Nuclear Regulatory Commission NSO Nuclear Security Officer

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! Attachment 1 4 l OSC Operations Support Center PA Protected Area

PDR Public Document Room (. P&lD Piping and Instrumentation Drawing t

QA Quality Assessment QS Quality Services RTV Room Temperature Vulcanizing SAS Secondary Alarm System SCBA Self-Contained Breathing Apparatus SEC Site Emergency Coordinator SG Steam Generator T&Q Training and Qualification TCD Telecommunications Department TSC Technical Support Center TS Technical Specification UE Unusual Event UFSAR Updated Final Safety Analysis Report URI Unresolved item VIO Violation l

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ATTACHMENT 2 Fire Barrier Penetration Seals inspected and Drawings Referenced Penetration Seal 2-BARR-2B/407-SOOO1 Penetration Seal 2-BARR-2B/407-SOOO2 Penetration Seal 2-BARR-2B/407-SOOO3 Penetration Seal 2-BARR-2B/407-SOOO4 Penetration Seal 2-BARR-2B/407-SOOO5 Penetration Seal 2-BARR-28/407-SOOO6 Penetration Seal 2-BARR-28/407-TOO1 Penetration Seal 2-BARR-2B/407-TOO2 Penetration Seal 2-BARR-2B/407 TOO3

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Penetration Seal 2-BARR-2B/407-TOO4 Penetration Seal 2-BARR-2B/407-TOO5 J

V Penetration Seal 2-BARR-28/407-C010 Penetration Seal 2-BAF?:-2B/407-C01 Penetration Seal 2-BARR-2B/407-C012 Penetration Seal 2-BARR-2B/407-C013 Penetration Seal 2-BARR-2B/407-C015 Penetration Seal 2-BARR-2B/407 C016 Penetration Seal 2-BARR-2B/407-C017 Drawing No. 62152 SHOO 24,Rev. 3, Barrier Segment Drawing for I'lant Elevation 45'-O" Drawing No. 61-406-A, SEC.108.0, Sheet 1, Rev. 2, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.0, Sheet 2, Rev. O, Fire Barriers / Stops ,

Drawing No. 61-406-A, SEC.108.1, Sheet 1, Rev. 3, Fire Barriers / Stops f Drawing No. 61-406-A, SEC.108.1, Sheet 2, Rev. 3, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.1, Sheet 3, Rev. 4, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.1, Sheet 4, Rev. 2, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.1, Sheet 5, Rev. 3, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.1, Sheet 6, Rev. 3, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.1, Sheet 7, Rev. 3, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.1, Sheet 8, Rev. 2, Fire Barriers / Stops Drawing No. 81-406-A, SEC.108.1, Sheet 9, Rev. 2, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.1, Sheet 10, Rev. 2, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.3, Sheet 1, Rev. 4, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.3, Sheet 2, Rev. 2, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.3, Sheet 3, Rev.1, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.3, Sheet 4, Rev.1, Fire Barriers / Stops Drawing No. 61-406-A, SEC.108.3, Sheet 5, Rev. 4, Fire Barriers / Stops Emergency Lighting Drawings Reviewed Drawing No. 63401 SHOO 28,Rev.13, Emergency Lighting & Communication Elevation 45'-O" Unit 2 Auxiliary Building Drawing No. 63402 SHOO 27,Rev. 9, Emergency LightinD & Communication Elevation 27'-

0" Unit 2 Auxiliary Building Drawing No. 61402 SHOO 36,Rev. 9, Emergency Lighting & Communication Elevation 45'-

0" Turbine Bldg. & Service Building Unit 1 & 2

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Drawing No. 61402SH0034,Rev.13, Emergency Lighting & Communication Elevation l 12'-O" Turbine Bldg., Service Bldg. & Intake Structure Unit 1 & 2 i Drawing No. 61402 SHOO 30,Rev.12, Emergency Lighting & Communication Elevation 27'-0" Unit 1 Auxiliary Building l

Drawing No. 61402SH0029,Rev.12, Emergency Lighting & Communication Elevation 45'-0" Unit 1 Auxiliary Building l

Fire Brigade Lesson Plans Reviewed Emergency Operations for the SCOTT 4.5 Pressure-Pak Fire Fighting Foam and Equipment NFPA 704 Haz-Mat identification System incident Command System i Fire Fighting Strategies Emergency Elevator Operations j

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l Emergency Response Plan and implementing Procedures Reviewed DOCUMENT DOCUMENT TITLE REVISION l N / CHANGE N ERPIP-OO5 Recovery Organization Notification 2 ERPIP-201 Technical Support Center Director 2/5

ERPIP-202 Plant General Manager 2/1 ERPIP-208 Plant Parameters Communications 1/1

! ERPIP-301 Operational Support Center 4 ERPIP-401 Nuclear Engineering Facility (NEF) 3 ERPIP-105 Control Room Communicator 3/2 ERPIP-108 Interim Radiation Protection O/1 ERPIP-209 Technical Support Center Communicator 3/2 l

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ERPIP-303 - Radiation Protection Director 1/3 l

ERPIP-310 Maintenance Team Leaders 2 ERPlP-312 First Aid Team Leader 1/3 ERPIP-315 Plant Parameters Communications-OSC O/5 ERPIP-322 First Aid Team Members 1/1 ERPIP-832 Emergency Work Permits 2/1 i

ERPIP-900 Preparation of Emergency Response Plan and 5 l Implementation Procedures

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Emergency Response Plan 23 l

ERPIP-OO5 Canceled 2 ERPIP-105 Control Room Communicator 3/3 ;

i ERPlP-209 TSC Communicator 3/3 ERPlP-509 EOF Communicator 3/3 ERP!P-750 Security 4/2 ERPIP-760 Plant Parameters Communications, Media Center 2/O ERPIP- Equipment Checklist 19/3 l

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e Attachment 3 2 DOCUMENT DOCUMENT TITLE REVISION N / CHANGE N ERPIP-105 Control Room Communicator 3/4

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ERPIP- immediate Action 18/9 ERPIP-102 Superintendent-Nuclear Operations 2/1 ERPIP-107 Interim Radiological Assessment 2/1 ERPIP-201 Technical Support Center Director 2/6 ERPlP-203 Chemistry Director 2/O ERPIP-301 Operational Support Center 4/1 ERPlP-311 Chemistry Team Leader 1/3 ERPIP-401 Nuclear Engineering Facility (NEF) Director 4/O ERPIP-501 Site Emergency Coordinator 3/1 ERPlP-503 Emergency Operations Facility (EOF) Director 3/O ERPIP-511 Radiological Assessment Director %

ERPIP-840 Canceled 3/0 ERPIP-841' Canceled 2/O ERPIP-842 Canceled 2/O E-Plan Attachment 1-2 (MAP) 24 ]

E-Plan Facilities and Equipment Section (#5) 24 ERPIP- Immediate Action 18/9 j ERPIP 801 CDA Using Containment Rad. Dose Rates %

ERPIP 803 CDA Using Hydrogen %

ERPIP 810 Main Steam System Radioactivity Release Es /0 ERPIP 308 Onsite Monitoring Team Leader O/3 ;

ERPIP 309 Dosimetry Team Leader 2/1 ERPIP 319 Dosimetry Team Members %

ERPIP 506 Offsite Monitoring Team Leader O/3 ERPIP 507 Offsite Monitoring Team O/7 l

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DOCUMENT DOCUMENT TITLE REVISION N / CHANGE NO.

ERPIP 720 Technical Representatives 2/2 ERPIP 750 Security 4/3 ERPIP Equipment Checklist 19/4 ERPIP 201 Technical Support Center Director 3/O ERPlP 319 Dosimetry Team Members %

ERPIP 105 Control Room Communicator 3/5 ERPIP 209 TSC Communicator 3/4 ERPIP 509 EOF Communicator 3/4 ERPIP 900 Preparation of Emergency Response Plan and 6/O Implementation Procedures ERPIP 210 CR/TSC Monitor 3/O l

ERPIP 308 Onsite Monitoring Team Leader 1/0 ERPIP 316 Operational Support Center Monitor 3/0 ERPIP 403 NEF Monitor- 3/O ERPIP 703 Nuclear Security Facility Monitor 1/0 ERPIP 750 Security 4/5

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1997 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 7(0) 8(0) 9(0) 10(0) 61(0) Security Operator Exams Emergency Planning Other