IR 05000317/1997007
| ML20199E607 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/27/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20199E592 | List: |
| References | |
| 50-317-97-07, 50-317-97-7, 50-318-97-07, 50-318-97-7, NUDOCS 9802020205 | |
| Download: ML20199E607 (42) | |
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. U.S. NUCLEAR REGULATORY COMMISSION
REGION I
License No DPR-53/DPR-69 l Report No /97-07 50-318/97 07 E Licensee: Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203 Facility: Calvert Cliffs Nuclear Power Plant Units 1 and 2 Location: Lusby, Maryland Dates: November 2,1997 through December 20,1997 Inspectors: J. Scott Stewart, Senior Resident inspector Fred L. Bower lil, Resident inspector Henry K. Lathrop, Resident inspector Ronald L. Nimitz, Senior Radiation Specialist, RI Thomas Mostak, Project Engineer, RI Approved by: Lawrence T. Doerflein, Chief Reactor Projects Branch 1 Division of Reactor Projects 9802020205 980127 gDR ADOCK 05000317 PDR
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b EXECUTIVE SUMMARY Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection Report Nos. 50 317/97-07 and 50 318/97-07 This integrated inspection report includes aspects of BGE operations, maintenance, engineering and plant support. The report covers a seven week period of resident 5 inspection and the results of a specialist inspection in radiation safet Plant Operations Plant operations were conducted well. The inspectors conducted daily reviews of control room operations and observed that the operators were both attentive arid responsive to plant conditions. The operations, maintenance, and engineering departments implemented multiple detailed on-line safety risk assessments for planned safety related equipment outages that included safety risk and trip risk assessments. Technical specification ,
. allowed outage times were implemented appropriatel BGE met their goals for reducing operator work around deficiencies and had aggressively
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categorized and evaluated work around deficiencies to minimize operational risk, Although
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there were severallongstanding work around deficiencies, no single deficiency nor the aggregate effect of the work around deficiencies represented a safety concern.
l The BGE Plant Operations and Safety Review Committee demonstrated a strong safety *
l perspective during observed meetings. The committee rejected poor quality assessments ;
and proposed activities. Split vote opinions did not involve safety issues'and were well-
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documente Maintenance Observed maintenance was conducted safely and in accordance with BGE approved procedures. Workers were knowledgeable and performed work effectively. Observed surveillance was conducted safely,
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'The inspectors considered the Calvert Cliffs housekeeping program to ba an effective l
initiative in identifying cleanliness problems and improving overall plant cleanliness. The i program also provided BGE with objective criteria to assess the adequacy of corrective actions for housekeeping deficiencie Enaineerina BGE had implemented an effective saltwater performance monitoring program in 199 However, the program guidance document was not maintained up-to-date and the program has not been continually implemented. Revisions to the program may be required after the installation of new service water heat exchanger , Although BGE efforts had been effective, the operability of the service water heat exchangers continued to be challenged by changing micro- and macro fouling. The ii
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Executive Summery (cont'd)
inspectors considered th'a potential for changing fouling factors and fouling rates will require continued BGE attentio Plant Support in general, radiological controls were appropriately implemented. Special work permit (SWP) and survey maps reflected protective measures and area conditions, respectivel Areas were found to be generally clean and well maintained. Workers were fcund to knowledgeable of the required radiological control However, the inspector found that the radiatica safety coverage requirements for fuel handling within the spent fuel pool were ambiguous and confusing. BGE implementation of a commitment to the NRC for continuous coverage during all work in the spent fuel pool was poor. Also, failure to conduct a survey as required by a work permit was a violation of NRC requirement BGE implemented a generally effective contamination control program. However, criteria for use in evaluating laundry selected for re-monitoring needed improvement. Review of the radioactive source term present within the station, relative h the effectiveness of instrumentation, remains to be comple' .
BGE provided generally conservative internal exposure control of its workers in its l application of a weighted derived air concentration (DAC) for potential exposure to airborne l transuranico. However, BGE reduced its transuranic DAC pending further evaluation of the l acceptability of general use of such a DAC for all exposure scenarios.
l BGE implemented a generally well defined sampling and analysis program in accordance with NRC Bulletin 80-10, Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolied Release to Environment. NRC review identified trace soil contamination (below REMP LLD valves) at station north outfall 002 and BGE initiated a review of this issu BGE implemented a generally effective external and internal dosimetry program BGE initiated very good efforts to ensure personnel were properly trained on new proceduros and procedure changes stemming from radiation protection improvement plan items. However, weaknesses were identified in training and qualification of newly appointed professionallevel personnel, ircluding the Radiation Protection Manager. In addition, all appropriate individuals did not receive training on revised procedu es.
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TABLE OF CONTENTS E X E C U TIV E S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii TAB LE O F CO NT ENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..............vi R e p o rt D e t ail s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. O p e r a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Summ ary of Pla nt Statu s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments (71707) ...........................1 02 Operational Status of Facilities and Equipment ................... 2 02.1 Safety Tagging (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 02.2 Engineered Safety Feature System Walkdowns . . . . . . . . . . . . . . 2 0.7 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 07.1 Operator Workarounds (71707) . . . . . . . . . . . . . . . . . . . . . . . . . 2 07.2 Plant Operations and Safety Review Committee (POSRC) . . . . . . . 4 08 Miscellaneous Operations issues (92700) . . . . . . . . . . . . . . . . . . . . . . . 5 08.1 (Closed) LER 50-317&318/97-002 . . . . . . . . . . . . . . . . . . . . . . . 5
! 08.2 (Closed) LER 50-318/9 7-00 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 l 08.3 (Closed) LER 50-317&318/9 7 001. . . . . . . . . . . . . . . . . . . . . . . 6 l
08.4 (Closed) LER 50-317&318/97-003 . . . . . . . . . . . . . . . . . . . . . .6 l
i 08.5 (Closed) LER 5 0-318 /9 7-001 . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 I 11. M a i nt e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 l M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 l M 1.1 G eneral Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . 7 M8 Miscellaneous Maintenance issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 M8.1 Pla nt House ke epiro . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 I l l . E n g i n e e ri ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 E2 Engineering Support of Facilities and Equipment .................. 9 E Saltwater (SW) and Service Water (SRW) Systems Continued Operability .......................................9 E2.2 3ervice Water Heat Exchanger Performance Monitoring . . . . . . . 10 I V. Pl a nt S u p p o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2 R1 Radiological Protection and Chemistry (RP&C) Controls ............ 12 R1.1 Applied Radiological Controls .........................12 R 1.2 Control of Radioactive Materials and Contamination . . . . . . . . . . 13 R3 RP&C procedures and Documentation ........................14 R3.1 Air Sample Counting and Analysis . . . . . . . . . . . . . . . . . . . . . . 14 R3.2 IE Bulletin 80-10 . . . . . . . . . . . . . . . . . ................ 15 R3.3 Radiological Controls (External Dosimetry Program) . . . . . . . . . . 16 R3.4 Radiolvgical Controls (Internal Dosimetry Program) .......... 17 iv v -
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Table of Contents (cont'd)
R3.5 Radiation Safety Coverage During Spent Fuel Pool Work ...... 18 R5 Staff Training and Qualification in RP&C . . . . . . . . . . . . . . . . . . . . . . . 19 R7 Quality Assurance in RP&C Activities . . . . . . . . . . . . . . . . . . . . . . . . . 21 R8 Miscellaneous RP&C Icsues . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . 23 R8.1 UFSAR Conformance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 R8.2 (Closed) Unresolved item (50-317&318/97-02-13) Review air sampling and analysis program . . . . . . . . . . . . . . . . . . . . . . . . 23 R8.3 Follow-up to NRC Inspection Report and Notice of Violation dated August 11,1997.................................. 23 R8.4 (Update) Violation (50 317&318/97 06-04 . . . . . . . . . . . . . . . . 24 R8.5 H ou s e k e e ping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 4 M
M anagement Mee tings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 X2 Review of UFSAR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 X3 Management Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 5 E
] ATTACHMENTS Attachment 1 - Partial List of Persons Contacted Inspection Procedures Used items Opened, Closed and Discussed List of Acronyms Used Attachment 2 - Radiation Protection improvement Agenda v
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Report Details 1. Operations Summarv of Plant Status Unit 2 had a small power reduction on Novembei 22,1997 to support scheduled maintenanco, otherwise, both units operated at full power throughout the inspection perio Conduct of Operations 01.1 Geneial Comments (71707)
Plant operations were conducted safety with a proper focus on continued nuclear safety. The inspectors conducted daily reviews of control room operations and observed that the operators were both attentive and responsive to plant condition On December 10, the inspector observed the operator response to a report of arcing ,I and sparking in the vicinity of scaffolding in a Unit 1 conta!nment purge fan roo An auxiliary operator was dispatched to the scene and the control room directed that personnel stay clear of the scaffolding. A plent electrician was summoned and a welding machine that was poorly grounded was de-energized. During the occurrence, communications remained formal as a senior reactor operator directed the plant response and reactor operators continuously monitored and evaluated plant conditions. The problem was documented as an issue report to ensure follow-up by the applicable work group. The inspector considered the operator performance to be very good and appropriate to the circumstance ,
l Licensed operator shift turnovers observed during the period were formal and l included control board walkdowns by the oncoming operators. The walkdowns were led by off going shift personnel. Equipment status was discussed and formal i reviews of safety equipment switch positions were completed. iollowing the shift l
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turnover, a pre-shift briefing was held with all of the plant opsrators. This briefing included security, chemistry, radiation safety, and fire protection personnel. Plant status was suinmarized and maintenance and evolutions to be conducted during the shift were discussed. The inspectors considered the shift turnover process to be complete and appropriat The inspectors conducted reviews of ongoing plant operations. In general, the conduct of operations was professional and safety-conscious. In planning for daily activities, the operations, maintenance, and engineering departments implemented multiple detailed on-line safety risk assessments for equipment outages that included safety risk and trip risk assessment. Maintenance was sequenced to minimize the risk factors. The applicable cystem Technical Specification (TS)
limiting conditions for operation (LCO) were entered and exited correctly for the equipment outage time _____
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02 Operational Status of Facilities and Equipment 02.1 - Safety Tagging (71707)
- insoection Scoce The inspectors reviewed the following tagouts: MO1199700429,12 high pressure
- safety injection (HPSI) Pump (in effect); M01199701446,1-MOV 665 (in effect);
and M0199701165,11 spent fuel pool (SFP) cooling pump & spent fuel pool cooling system check valve 0-CKV SFP-102 (no longer in effect). Observations and Findinos For those tagouts in effect, the inspectors verified that the tagouts were properly prepared and authorized. The inspectors confirmed that the specified components l
were properly tagged and where possible verified that the components were in the required positions. For those tagouts no longer in effect, the inspectors verified that the tags were removed and equipment was restored as require c.- Conclusions The inspectors concluded that the safety tagging clearances reviewed were prepared, authorized, hung, and removed properl .2 Engineered Safety Feature System Walkdowns (71707)
y The inspectors conducted a walkdown of accessible portions of the containment atmosphere hydrogen analyzer system. Equipment configuration was consistent with plant drawings. Equipment material condition and housekeeping in the areas were good. One system deficiency had been assessed for operability and there were no significant problems identified. Indications of hydrogen concentration in containment were available in the control room and locally at the anslyzers. In event that the system was inoperable, a local manual sampling location was available and procedures for obtaining a manual sample were complete. The inspector considered the system to be in the proper state of readiness should containment hydrogen monitoring be necessar .7 Quality Assurance in Operations 07,1 Operator Workarounds (71707) Insoection Scoce 5 -
The inspectors reviewed operator workarounds and implementation of a BGE operations department process for correcting these deficiencie ______J
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3 Observations and Findinos The BGE operations department had implemented a program to evaltste and minimize operator workarounds. An operator w7k around was defined as any deficiency or non-conforming condition that complicated the operation of olant equipment and was compensated for by operator action. Operations assigned a licensed senior reactor operator the collateral duty of trending work around deficiencies and developing a monthly status report that included age of the problem and projected repair date. Also, each work around deficiency was categorized and evaluated to determine the individual and aggregate effect on plant operation and safet The inspector reviewed the November monthly report and noted that the impact of compensatory actions on each watch station was evaluated. No watch station was affected by more than two compensatory actions. Systems were evaluated for the aggregate effect of more than one work around. Five systems had more than one work around with six workarounds for the Unit 2 main turbine being the system
- with the greatest number. The affect of operator workarounds on personnel and I
radiation safety, plant transients and trips, reactivity management, and AOP and EOP performance were also evaluated in the monthly report. BGE concluded that I no workarounds presented personnel or radiation safety concerns.
i One BGE goal was to have the operator workarounds ready to work within thirty days of identification. The inspector noted that the November 1997 report identified that 13 of the 17 items that could be worked in Mode 1 were not meeting the goal of being ready to work within 30 days. Additionally, the oldest item, requiring manual operation of the Unit 2 main turbine steam seal regulator during transients, was over 700 days old. As noted previously, this item posed some transient and :eactivity management ris The inspectors also reviewed the trend for the last year. The inspectors noted that the numbar of operator workarounds was declining with 39 in November 1996 and 32 in Novemoer of 1997. BGE was meeting the sstablished goal of 35 total operator workarounds for both units. RGE informed the inspectors that they planned to set a lower goal in 1998, Conclusions The inspectors concluded that BGE met their established goals for reducing operator work around deficiencies and had aggressively categorized and evaluated work around deficiencies to minimize operational risk. Although there were several longstanding work around deficiencias, at the time of the inspection, no single deficiency nor the aggregate e'fect of the work around deficiencies represented a safety concer l m o
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07.2) Plant Operations and Sdety Review Committee (POSRC) Inspection Scope (71707L The inspectors reviewed and observed activities undertaken by the POSR Observations and Findigga-
The POSRC was responsible for the review of items affecting plant / nuclear safety, such as safety related procedures, tests, modifications, and safety evaluation During a meeting on November 3, the committee displayed a very strong safety perspective in thei_r evaluation of problems with the spent fuel storage casks and their potential for adversely affecting the upcoming refueling outage _of Unit 1 and the ability to off-load the entire reactor core, if necessary. At another meeting, the " j'
committee was highly critical of the way the plant was responding to issues n ' surrounding the remuval from service of both Appendix R and non-safety related fire detection and suppression equipment. The committee was concemed that some
- fire protection equipment would often be out of service for a much longer time tbn warranted by the work being done, thereby raising the risk to safe plant operatio Based upon the review, plant maintenance and operations revised their plans for control of fire detection equipmen The inspectors ted that personnel giving presentations to the POSRC were typically well prepared and able to satisfactorily respond to committee question However, the inspectors noted that the POSRC on several occasions engaged in lengthy discussions designed to enhance the quality of the product being presented, resulting in the co mittee becoming part of the process rather than a reviewer and assessor of the sarety and quality aspects of the issue. - The inspectors concluded that this behavior on the committee's part was infrequent, as most inferior presentations were withdrawn by the presenters prior to a POSRC vote. The -
POSRC chairman informed the inspactors that several methods to improve presentation quality had been'imple iented, including providing feedback to the presenter's supervisor and quarterl self-assessments by POSRC on their
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The inspectors questioned the policy of allowing split votes on recommendations for approval. The POSRC chairman indicated that split votes were relatively rare (about
- 10 per cent of all votes) and that both the majority and minority views were
. available for the plant general manager's review, who would later explain to POSRC his decision on the split vote and the reasoning behind it. The inspectors noted that all the split votes observed dealt with technical as opposed to nuclear safety issue Any safety concerns were resolved prior to voting. The inspectors also noted that the minutes of the POSRC meetings had been enhanced to include more detailed notes on both majority and minority positions. The minutes were reviewed and discussed, as needed, by the off-site safety review committee, which maintained an oversight of the POSR __ _ ___________ _ _ _ _ _ _ - . . .
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.] Conclusions The inspectors concluded that Plant Operations and Safety Review Committee demonstrated a strong safety perspective during the observed meetings. The committee rejected poor quality assessments and proposed activities. Split vote opinions did not involve safety issues and were well-documente Miscellaneous Operations issues (92700) l 08.1 (Closed) LER 50-317&318/97-002: Misread Technical Specification Results in inadequate Test
The Licensee Event Report discussed a determination by BGE that the surveillance '
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testing for the emergency diesel Cenerators did not meet Technical Specification 4.8.1.1.2.d.3.c. The requirement was a periodic verification that non-critical diesel engine trips were automatically bypassed on a safety injection actuation signal in conjunction with a loss of offsite power. The testing that was performed prior to the determination showed that the non critical trips were bypassed on safety injection only. BGE successfully tested the diesel circuitry and revised applicable procedures. ' Additionally, the plant general manager informed station personnel of a j need te be sensitive to exact technical specif: cation wording. The inspectors
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review' d the occurrence using NRC Enforcement Guidance Memorandum 97-012A and de' irmF.ed that a non-cited violation was appropriate in accordance with NRC Enforcen.ont Policy Vll.B.1. The LER is closed. (NCV 50 317&318/97-07-01)
08.2 (Closed) LER 50-318/97-002: Containment Purge Valve Isolation The LER deturibed that core alterations had been performed on Unit 2 with the containment purge valve isolation system inoperable and with the personnel airlock open. Unit 2 Technical Specification (TS) 3.9.9 stated that with the containment purge valve isolation system inoperable during core alterations, each of the penetrations providing direct access from the cnntainment atmosphere to the outside atmosphere will be closed. The containment purge isolation valves were shut for the duration of the event. The inspectors noted that Technical Specification 3.9.4 provided specific requirements during core alterations for control
. of containment penetrations including the containment airlock. BGE was in complianc3 with this technical specification during the core alteration activities described in the LER. Further, NRC NUREG-0212, Revision 2, Standard Technic-l Specifications for Combustion Engineering Pressurized Water Reactors, stated in Technical Specification 3.9.9, that with the containment purge valve isolation system inoperable, c ring core alterations, close each of the " containment purge" penetrations providing direct access from the containment atmosphere to the outside atmosphere. BGE was in compliance with this standard technical specification during core alteration activities described in the LER. Unlike the standard technical specification, the Calvert Cliffs technical specification did not include the words " containment purge;" however, based on discussion with the
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l Office of Nuclear Rcautor Regulation staff, the inspectors noted the intent of the specification was to apply the specification to those components affected by the ;
containment purge isolation system inoperability.-- Based on these determinations, . l the inspectors concluded that this feilure to meet TS 3.9.9 conctitutes a violation of minor significance and is being treated as a Non-Cited Violation consistent with section IV of the NRC Enforcement Policy. (NCV 50 318/97 07-03) The LER is close .3 (Closed) LER 50-317&318/97-001: Spent Fuel Moves with Ventilation inoperable The LER described a January 10 occurrence where spent reactor fuel was being moved in the spent fuel pool without meeting the technical specification requirement for exhausting fuel pool ventilation through charcoal filters. The issue was described in NRC Inspection Report 50 317&318/9610,and was cited as a ,
violation of NRC requirements. Corrective actions included evaluation of air leakage into the spent fuel pool area and procedure revisions. Additional problems were identified with the handlag of spent fuel and alignment of ventilation as discussed in NRC Inspection Report 50 317&318/97-02. These problems were the subject of a predecisional enforcement conference and additional corrective actions were identified. The LER is close .4 (Closed) LER 50-317&318/97-003: Spent Fuel Moves without Charcoal Filters The LER desc ibed an April 24,1997 occurrence where fuel was moved in the spent fuel pool without meeting the technical specification requirement for t exhausting fuel pool ventilation through charcoal filters. The problem was included i-in an NRC enforcement action taken in conjunction with NRC Inspection Report 50 317&318/97-02. Comprehensive correct!/e actions were specified in the BGE response to the notices of violation issued as part of the enforcement action. The LER is close .5 (Closed) LER 50-318/97-OO1: Refueling Machine 0 erload Circuit inoperable The LER described an April 1,1997 occurrence where fuel was moved with the Unit 2 refueling machine when overload protection was cutout during part of the fuel travel. The problem was identified by BGE during a review conducted for other identified problems with refueling equipment. The event was included in an NRC enforcement action taken in conjunction with NRC Inspection Report 50-317&318/97 02. Comprehensive corrective actions were specified in the BGE response to the notices of v:olation issued as part of the enforcement action. The LER is close .
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II. Maintenance
'M1 Conduct of Maintenance M1.1 ' General Comments
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a .= - Inspection Scone (62707) 1 The inspectors reviewed maintenance activities ano focused on the status of work '
L that involved systems and components important to safety. Component failures or L system problems that affected systems included in the BGE maintenance rule F program were assessed to determine if the maintenance was effective. Also, the
!' inspectors directly observed all or portions of the following work activitie MOO 199702460 Replace OCKVSFP-102 Hinge Pin Bushing-M01199602765 Replace Inboard and Outboard Seal on' 12 HPSI Pump M01199706032, Troubleshooting and Ther.aography of VCT Levd MO2199701131 Clean Tubes for 22 Service Water Heat Exchangar
- Observations and Findinas The inspectors found that the selected maintenance activities were performed safely ano in accordance with approved _ procedures. Technicians were experienced and
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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.-
When applicable, appropriate radiation control measures were in place and foreign material exclusion controls were practiced.' The inspectors noted that an
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appropriate level of supervisory attention was given to the wor : Conclusions The observed maintenance was conducted safely and in accordance with BGE
. approved procedures and controls. Workers were knowledgeable and performed work effectivel M1.2 Routine Surveillance Observations Inspection Scone (61726)
The inspectors observed all or portions and reviewed selected surveillance tests:
STP-073F-1 11 Boric Acid Pump Performance Test OI-21C OC Emergency Diesel Generator Slow Speed Start
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8 Findinas and Observationc The observed surveillance testing was performed safely and in accordance with approved procedures. Pre-test briefings included means of communication, test control details, and contingency actirms such as actions to be taken should the boric acid system relief valve lif t. The inspectors noted that an appropriate level of supervisory attention was given to the testing including direct observation of test steps. The inspector found that approved procedures were in use, details were adeouate, technical specifications were satisfied, testing was performed by qualified personnel, and test results satisfied acceptance criteri Cor clusions The observed surveillances were conducted safety and effectively demonstrated system operabilit M8' Miscellaneous Maintenance issues M8.1 l . ant Housekeeping Insoection Scoce (71707)
The inspectors reviewed BGE's implementation of an enhanced plant cleanliness program using objective rating criteria to rate a specific area and provide data for the tracking and trending of cleanliness issues, j Observations and Findingg BGE had implemented an enhanced plant cleanliness tracking program to better assess general plant housekeeping. The program included all safety and non-safety related areas and structures within the protected area except for radiologically controlled areas (such as the auxiliary building or containments). Each area or structure was objectively rated on eleven criteria (each criterion was assigned a point value, with 100 points totai). Among the more significant c"teria were:
- preventive measures taken to limit the spread of debris from in-progress jobs, e no dust on plant equipment, e no leaks, or existing leaks contained / barricaded, e trash cans and oil rag bins are emptied, and
- no uncontrolled or improperly placed debris found in the are The ratings ran from " excellent" (90-100 points), " good" (80-90 points), "f air" (70-80 points), to " poor" (less than 70 points). BGE management expectations were to maintain at least 80 points for each area / structure evaluated. For the months of November and December,1997, the site averaged 91.0 and 89.9 points, re3pectively. The inspectors noted that BGE had used the results of the evaluations to target and correct several chronic problem areas, such as the main condenser
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pits and the intake etructure, in the fall of 1997, radiological controls personnel initiated the use of a similar scoring system for radiologically controlled areas on site. Based in part on reviews of their results, BGE began a comprehensive effort in December to reduce the amount of extraneous and unused materialin the auxiliary building. While ongoing when the period ended, the inspectors noted that already significant amounts of material and equipment had been decontamuated and disposed of, resulting in a substantial improvement in the building's cleanliness and appearanc Conclusions The inspectors considered the Calvert Clifis housekeeping program to be an effective initiative in identifying cleanliness problems and improving overall plant 1"
cleanliness. The program also provided BGE with objective criteria to assess the i
adequacy of corrective actions for housekeeping deficiencies, Ill. Enaineerina
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E2 Engineering Support of Facilities and Equipment E2.1 Saltwater (SW) and Service Water (SRW) Systems Continued Operability !nsoection Scooe (92903) The inspectors reviewed the BGE efforts to ensure continued service water system operability and reliability. The inspectors also reviewed the BGE heat exchanger performance monitorin Findinas and Observations in January 1996, BGE determined that the equilibrium micro-fouling factor assumed in the service water heat exchanger thermal performance calculations was less than an empirical value obtained from an installed side stream fouling monitor. This issue was discussed in NRC Inspection Report (IR)
50-317&318/96-01 and in BGE Licensee Event Report (LER) 50-317/96-0 The LER was supplemented in October 1997 to report on continuing engineering work, corrective actions, and increased fouling that had been identified in continued testing. In NRC Inspection Report 50-317&318/96-06,the effectiveness of the BGE corrective actions for service water heat exchanger inoperabilities due to fculing were identified as an unresolved issu NRC inspection Report 50-317&318/97-03and LER 50-317/96-01-01 described the BGE preparations and actions implemented for the Chesapeake Bay water temperatures during the summer of 1997. The actions taken included cleaning biological growth from the saltwater system inlet piping; modifying the emergency diesel generator control valves air supply; and, coordinating the scheduling of heat exchanger cleanings te minimize system unavailability. The
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10 LER supplement provided a detailed description of the operating instruction used to monitor the SRW heat exchangers using bay water temperature, tube side differential pressure, and tube side saltwater flow. BGE was aided by normal bay conditions during the summer of 1997 that were favorable from a heat exchanger fouling perspective and the result was that the heat exchanger operability was not significantly challenged throughout the summe LER 96-01 also described the BGE plan to replace the existing SRW heat exchangers with larger heat transfer capacity, plate and frame heat exchanger The replacements were planned for the 1998 refueling outage for Unit 1 and the 1999 refueling outage for Unit 2. In the interim, BGE intends to continue to monitor fouling using the installed side stream monitor. Unreselved item 50 317&318/96 06 03and LER 50-317/96-001 are close E2.2 Service Water Heat Exchanger Performance Monitoring At the time of the NRC service water operational performance inspection (SWOPI) in 1994, BGE had not established a formal periodic test program for
., their safety related heat exchangers. This program was recommended by NRC 1~ Generic Letter 89-13, Service Water System Problems Affecting Safety Related Equipment. BGE position paper, "GL 8913 Task ll Status," dated March 10, 1994, stated that the development of a continuing heat exchanger test program document was acheduled for completion by June 30,1994. BGE established a continuing program to verify the thermal performance of safety related heat exchangers and coolers that use the saltwater system as a direct heat sink in plant engineer'a j guideline (PEG) 5, Sultwater System Operational Performance Program (SWSOP), Revision 0, dated June 19,1994. The inspectors reviewed the program and determined that a reasonable performance monitoring program had been established. However, the inspectors noted that changes to the program had not been incorporated into PEG 5. For example, PEG 5 stated that preventive maintanance to clean (bullet) the SRW heat exchanger tubes would be scheduled and performed every 12 weeks. However, the inspectors observed and LER 96-01 reported that the scheduled SRW bulletings were concentrated in the sumrner with additional cleanings performed as neede PEG-5 stated that a semiannual assessment of all heat exchangers in the BGE program would be conducted to determine if the test, inspection, and monitoring methods ensured that safety functions were maintained. The results of the semiannual review were to be reported to management. The inspector reviewed a report dated February 28,1995, and determined that the report provided the information and format specified by the engineering guideline. The information and analysis were thorough and detailed. However, discussions with BGE personnel indicated that subsequent semiannual reports were not done. BGE personnel ,
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indicated that some of the performance information was reported to management in BGE system report cards. BGE engineering personnel initiated an issue report to document this problem. P ant engineering personnel stated an htent to develop and issue a performance monitoring report to resolve this issu _ _ .
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The inspectors reviewed the BGE efforts taken to address the service water system operational performance inspection issues discussed in NRC Unresolved items 50 317&318/94 80-01and 94 80-03. These issues were related to a BGE effort to increase the salt water intake temperature limit and included the following items: At the time, BGE had not reviewed the aggregated impact (frequency of the occurrence and duration) of the service water header unavailability as a result of the assumed fouling. Also, BGE reviews had not considered the accuracy of saltwater differential prescure readings given the oscilleting nature of indication of the Individual pressure gauges used for heat exchanger differential pressure determination. The impact of these factors was to be reviev*ed by BGE as part of an operating instruction revision for the service water syste . BGE had not verified the fouling factors used in the heat exchanger design calculations.
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Following the NRC inspection, BGE installed oil filled and damped differential pressure (d/p) gauges to monitor heat exchanger d/p and address c ncerns related to the oscillation of the indi"Must pressure gauges. BGE documented the methodology for incorporating instrument accuracy into the differential pressure limits for the service water heat exchangers, l
I Although ab found thermal performancs testing of the heat exchangers had not been performed, BGE installed a side stream monitor (SSM) to model I tube side microfouling. The resu'ts from SSM testing have been used to l update the design basis calculations. BGE reprted on the use and results of
} the monitor in LER 50 317&318/96-01. The inspectors observed that BGE performance snonitoring reports and system report cards included service and saltwater system unavalla.)ility. Additionally, BGE risk assessments for the maintenance and scheduling process considered cumulative unavailabilit The ins,nectors found that B'3E effectively managed the service water heat excht.nger unavailability in 1997 using maintenance planning and other actions. % '.en operability was effectively monitored using system operating instructions. Changing heat exchanger fouling and the need to revise operability limits had been considered by BGE and revised operability limits were proceduralized and implemented. The new limits accounted for instrument inaccuracles. Unresolved items 50 317&318/94 80 01and 94-80-03 are close _
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. .Qgpflusions The inspectors concluded that BGE had implemented an effective saltwater ,
performance monitoring program in 1994. The initial performance monitoring report was thorough and detailed. However, the program guidance document was not maintained up to date and the progw.m has not been continually implemente Revisions to the program may be required after the installation of new service water heat exchanger BGE effectively implamented the operating procedures and corrective actions necessary to maintain the operability and reliability of the SRW heat exchanger '
Although the BGE efforts had been effective, the operability of the service water heat exchangers continued to be challenged by changing micro- and macro fouling, i The inspectors considered the potential for changinq fouling f actors and fouling rates will require continued BGE attention.
1-IV. Plant Suonort Fi1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Applied Radiological Controls Insoection Scone (83750)
The inspectors toured various site radiological control areas (RCA), including tne 14siterials Processing Facility, the Interim Spent Fuel Storage Installation (ISFSI),
ISFSi equipment storage building,' and Instrument Calibration Shop. The inspectors reviewed general applied radiological controls including posting, barricading and i access control; use of radiation work permits; and perso..nel monitoring practices, Observations and Find p1 i The inspectors verified that proper warning signs were posted, personnel access -
was controlled, Special Work Permits (SWP) were posted, survey rnans were current, monitoring instruments were functional and in-calibration, and personnel were wearing the proper dosimetry. Station areas toured were generally clean, with equipment neatly store BGE personnel interviewed by tho inspectors were generally knowledgaabte of current and prospective operations and were aware of radiological conditions in their areas. Personnelleaving areas were prcperly monitorod for radioactive contaminatio Conten.:nated equipment was appropriately labsled and warning signs were in place identifying potentially contaminated areas. Workers were found to be aware of radiological conditions and requisite controls in their area, a
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13 Conclusions Radiological controls were appropriately implemented for the areas toured. SWP and survey maps reflected protective measures and area conditions, respectivel Areas were found to be generally : lean and well maintained. Workers were found to knowledgeable of the required radiological controls. No violations or sr.fety concerns were identifie R1.2 Control of Radioactive Materials and Cantamination Insocction Scope (83750)
l The inspector selectively reviewed control practices for radioactive material and contamination during tours of the station, Observations and Findinos Monitorino and Control of Lsu ,drv BGE used the services of a commerciallaundry to launder reusable protective clothing (e.g, boots, coveralls, etc.). When the cleaned laundry was returned to BGE,it was BGE's practice to sample and re-monitor a fraction of the laundry ac a quality control check of the commerciallaundry service. A violation was issued in NRC Inspection Report 50 317/318/97 06 associated with lack of a description of a program for monitoring the laundry and actions to be taken when contaminated laundry was identified. Personnel were noted to have sustained contamination from protective clothin The inspector review 0d the prog *am procedure established for monitoring of laundry upon its return from the commercist laundry service. The inspector had the following concerns with the procedure, j
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The sampling criteria did not appear to be statistically determined, it was not !
clear what the technical bases were for the sample size of laundry to be l remonitore There was no guidance as to what actions were to be taken when a piece of re monitored laundry indicated significant levels of residual contamination
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despite the piece of laundry being part of a limited population of contaminated laundry. The program was unclear as to what lovels of contamination on single laundry items would require prompt action to remove laundry from general worker us The licensee initiated action to review these matter , ..
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General Contamination Cortrol The inspector's tours of the station indicated that BGE !mplemented generally effactive contamination controls. BGE continued to implement a multi monitet personnel contamination monitoring program. Personnel exiting the radiological controlled area were monitored by both beta and gamma radiation detection systems.
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Proaram Reviews During a prev 80us inspection, the inspector noted that BGE did not have a clearly defined program to inter-compare the station's radiation environment (e.g., radiation types and radiation energies) with antt' sis instrument calibration and chsck source characte:istics to ensure calibration.J the instruments was proper (e.g.,
determination of appropriata instn ment efficiencies).
The inspector noted BGE was perfonalng a comprehensive review of its in plant radionuclide mix in order to provide for effective calibration of radiation and contamination monitoring system BGE had re evaluated the efficiency of its hand held friskers and noted a decrease in frisker efficiency. BCE was evaluating the efficiency decrease and the need to revise personnel and material monitoring requirements, Conclusions BGE implemented a generally affective contamination control program. However, criteria fcf use in evaluating laundry selected for re monitoring needed improvemen Review of the radioactive source term present within the station, relative to the effectiveness of instrumentation, remains to be complete R3 RP&C procedures and Documentation R3.1 Air Sample Counting and Analysis . insoection Scope (83750)
The inspector selectively reviewed BGE's air sample analysis program. In particular, the inspector reviewed the selection of a derived air concentration (DAC) for use in controlling exposure attributable to transuranics. This matter had been previously discussed during inspection 50-317/318/07-02. At that time, the inspector questioned the basis for using a DAC that was not specifically listed in 10 CFR 20, Appendix B,' for monitoring and control of personnel exposure to transuranics. BGE had developed and was using a " weighted" DAC for exposure control purpose .c , _ ~
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15 Observations and Findinas The inspector discussed the above observations with cognizant licensee personnel and noted that the licensee had relied on composite smear sample results collected under the 10 CFR Part 61 program for dry active waste (DAW) analysis. It was not immediately apparent that this technique boundad all potential exposure situations and that the weighted DAC provided conservative exposure controls for all expected exposure scenarios. BGE noted that the limitation of this practice was the belief that the DAW radionuclide mix adequately reflected or at least bounded the actual airborne radioactive meterials encountered by workers. BGE did perform a limited study involving two air samples associated with reactor flange work and noted the weighted alpha DAC provided a conservative DAC fraction for expocure control purpose To enhance its ability to evaluate potential airborne incidents, BGE initluted actions to routinely analyze composite air samples from outage and balance of plant work activities. BG3 also re adjusted its DAC for transuranics to provide for exposure control using the most restrictive transuranic DAC provided in 10 CFR 20 for radionuclides expected to be present in a reactor environmen The inspector noted that BGE also evaluated filter loading and concluded that procedures provided adequate guidance for considering possible filter loading commensurate with r.ir sample flow rates used and air sample volumes collecte BGE concluded that filter loading would not adversely affect alpha transmission for air sample analysis and conservative alpha transmission factors were used.
I Conclusion BGE provided generally cunservative internal exposure control of its workers in its applicadon of a weighted DAC for potential exposure to airborne transuranics.
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However, BGE reduced its transuranic DAC pending further evaluation of the I acceptability of general use of such a DAC for all exposure scenarios.
l l R3.2 IE Bulletin 80-10 Scooe (83750)
The inspector selectively reviewed BGE's sampling and analysis program established in response to NRC Bulletin 8010," Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release to Environment," dated May 6,1980. The NRC issued the bulletin to provide for monitoring of non-contaminated systems that interfaced with contaminated systems and to provide for prompt identification of cross contamination between systems that could result in an unmonitored releaso of contamination to the environmen _ _ _ _ - _ _ -
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16 Observations and Findings The inspector selectively reviewed BGE's IE Bulletin 8010 sampling and analysis program and noted it to be generally comprehensive. A detailed sampling and analysis program was established including lower limits of detection and action levels based on contamination levels identified. BGE had developed a priori safety evaluations in the event of system cross contaminatio '
The inspector's review of the program identified the following:
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In an effort to Identify potential unmonitored selease paths, the inspector performed soll sampling at the north outfall (002)in a marsh area. The soil sample was counted by BGE using its standard counting protocols and low level Co-60 contamination was detected in soil at the location. A water sample collected at the location, when analyzed, did not indicate any radioactivity associated with reactor operations, including tritium. The Co 60 soll activity (0.0235 pCi/gm * 0.0072 pCilgmi was well below typical Radiological Environmental Monitoring Program Lower Limits of Detection (REMP LLD) values (0.15 pCi/gm). Cs 137 was also detected (0.0315 pCi/gm 0.0065 pCi/om) but this activity was celleved to be attributable to fallou BGE reviewed this matter and believed that the Co-60 contari.ination was j attributable to trace activity that may be in the discharge from turbine i building sumps. The sump discharge pathway was a recognized effluent
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release point and was included in olfsite dose calculation The inspector noted soll was not collected at south outfall 004 due to the nature of the release point (directly into the bay). A sample of discharge water was analyzed with no detectable activity note BGE initiated a review of the above matter, Conclusion BGE implemented a generally well defined sampling and analysis program in accordance with NRC Bulletin 8010. NRC review !dentified trace coil contamination (below REMP LLD velves) at station north outf all 002 and BGE initiated a review of this issu R 3.3 Radiological Controls (External Dosimetry Program) Insoection Secoe (83750)
The inspector selectively reviewed the capabilities of the I;censee's personnel monitoring devices and its use of dosimetry accredited by the National Voluntary Laboratory Accreditation Program (NVLAP).
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17 Observations and Findinos BGE implemented and continued to maintain its own in house personnel monitoting program including processing of personnel monitoring devices. BGE held a valid NVLAP accreditation for al applicable testing categories for whole body dosimew,.
BGE subjected its electronic dosimetry to similar testing and concluded that the electronic dosimeter performed well relative to expected radiation energies to be encountered at the station. The electronic dosimeter was noted to provide a 1 3%
over respons BGE's performed extremity monitoring using the TLDs accredited under its NVLAP progra Conclusion BGE implemented a generally effective external dosimetry program. No violations or sdiety Concef ns Were identifie R3.4 Radiological Controls (Internal Dosimetry Program) inspection SconeJ83750)
The inspector reviewed the capabilities and testing of the licensee's wholn body counting equipmen Observations and Findinas The inspector noted that BGE performed a number of evaluations of its whole body counter including site acceptance testing. The testing indicated the whole body counter performed well for normally encountered radionuclides, BGE's internal dosimetry program provided for review and evaluation upon indication of intake of radioactive material. BGF's plant health physics staff cvaluated whole body counter analysis results and revised or amended the results, as appropriate, for hard-to-detect or non-detectable radioactivity (e.g., alpha emitters).
The following observations were mad BGE provided for a normal one minute count when whole body counting personnel. BGE was using a limited radionuclide library for this countin The inspector noted that although the limited library orovide principal radionuclides, an expanded library was available for use and improved detection capability was possible using relatively minor increases in personnel count times (i.e., two minutes versus one minute).
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18 Conclusion BGE implemented a generally effective internal dosimetry piograns. No violations or i
safety concerns were identified. However, areas for improvement were noted, l
R3.5 Radiation Safety Coverage During Spont Fuel Pool Work j i inspection Scot.e (71750)
The inspectors reviewed radiation safety controls during work in the spent fuel pool area, Findinas and Observations As a result of an NRC Notice of Violation issued with NRC Inspection Report 50-317&318/82-00,BGE committed that a specific special work permit (SWP) would be written snd would require continuous radiation safety technician coverage for any maintenance work in the spent fuel pool regardless of work scope. BGE promulgated thic commitment by including it in Calvert Cliffs procedure RSP-1201, SWP Preparutlori.
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The inspector observed that Special Work Permit SWP 100, dated December 31, 1996, for fuel shuffie within the spent fuel pool, spcen,ed contiruoun radiation safety technician coverage. However, the SWP had been revised on January 8, 1997 to allow RST coverage "as assigned per radiation controls shift supervisor for handling machine operations." The SWP also stated that removal of items from the spent fuel pool was not allowed and specified that a radiation survey be conducted once per shift while working in the spent fuel pool are On November 6, the inspector observed two plant operators entering the fuel pool area, accompanied by a radiation controls technician. The operators were conducting fuel shuffle operations in the pool. After completing a survey of the refueling bridge, the radiation safety technician left the fuel pool area and began other duties on the auxiliary building level, in the vicinity of the spent fuel pool are The technician, when questioned, stated that a survey of the handling machine had been done. When radiation safety supervisors were questioned by the insocctor, they stated that continuous coverage required by the SWP could include other work on the level. The supervisors volunteered that a problem with RSP 1201 had been identified and that the coverage requirement of SWP-100 was ambiguous. The supervisors stated that continuous radiation safety technician presence on the level met the intent of the SWP specified coverage. The supervisors further stated that continuous monitoring during fuel shuffle provided no safety benefit because radiation levels did not change. The supervisors stated that continuous monitoring would be appropriate for any activity that involved removing items from the pool or the potential for a radiation source to breach the water shiel .
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The inspector reviewed records of entries made into the spent fuel pool area using SWP 100. The inspector noted that on September 11,1997, no radiation safety technician had entered the spent fuel pool foreign materials control area although numerous operations personnel had conducted work under SWP 100. On quutioning, BGE stated that no record of a once per shift raolation survey could be found for September 11,1997. Failure to conduct a once per shift survey as required by SWP 100, while working under permit SWP 100 was a violation of NRC requirements. (VIO 50 317&318/97 07 02)
The inspector was informed by BGE that monthly surveys of the refueling bridge
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BGE supervisors stated that the coverage for fuel handling had been interpreted differently by various radiation safety technici.'ns,
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l SWP preparation procedure, RSP 1201 had been revised on September 12,1997.
l In the revised version, the requi.ement for continuous coverage had been revised to l
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allow for some work to be accomplished without cont!nuous coverage. Also, the definition of continuous coverage was revised to be consistent with other radiation safety program definitions. The inspector observed that the revised definition was identical to that for spot check coverage and allowed for performing periodic radiation surveys at the frequency specified by the SWP. Radiation safety supervisors stated that the survey frequency would be commensurate with the risk ( of the individual task t'elng complete Conclusions The inspector found that the radiation safety coverage requirements for fuel handling within the spent fuel pool were ambiguous and confusing. BGE implementation of a commitment to the NRC for continuous coverage during all work in the spent fuel pool was poor. Also, failure to conduct a survey as reoulred by a work permit was a violation of NRC requirement R5 Staff Training and Qualification in RP&C Scooe BGE recently rotated personnel within the radiation protection organization in order to provide for enhanced performance and assignment of personnel to specific program enhancement tasks. The inspector selectively reviewed the qualifications of recently rotated and newly selected personnel within the radiation protection organization. The review was with respect to criteria contained in Technical Specification _
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b. ObservatLqns and Findinas httsonnel Qualifications The inspector reviewed the qualifications of the now Supervisor Radiation Control and noted that this individual met experience requirements outlined in Technical Specifications. The individual had a working f amiliarity with applicable operations radiation safety program procedures since he had previously held the ALARA Supervisor position. However, BGE did not evaluate this individual's specific f amiliarity with all appropriate procedures that this individual would be requ3 red to implement (or assure proper implementation by subordinates) prior to assigning him full responsibility and authority as Supervisor Radiation Control. This was considered a weaknes BGE also selected a new ALARA Supervisor. The inspector had no immediate questions relative to this individual's qualifications. The individual was noted to have significant involvement in PWR industry ALARA program review and enhancement effort The inspector reviewed the qualifications of the newly appointed Radiation l
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Protaction Manager (RPM). This individual did not appear to posses the requisite five years of professionallevel radiation protection experience specified in Regulatory Guide 1.8. The individual possessed significant chemistry experience and technician experience which was not directly creditable toward the five year experience criterion. The inspector's review indicated the individual possessed approximately three years of creditable experienc In light of the above, and subsequent to the inspection, the licensee provide the NRC a letter dated December 22,1997, which indicated that, pending qualification of the selected individual as RPM, an interim, qualified RPM was selected who would be responsible for the management of the radiation protection program at Calvert Cliffs including approval of pertinent procedures. This individual would also sit as a member of the plant operation and safety review committe BGE indicated in its letter that an appropriate training and coaching program would be established for the selected RPM and an evaluation would be conducted for recently appointed radiation safety personnel to determine the need for any additional training. Additional training would be conducted, as appropriat Based on the above, the inspector made the following observation In early December 1997, BGE selected a new RPM who did not meet applicable qualification criteri BGE did not formally evaluate a new supervisor's f amiliarity with applicable program procedures prior to assigning him full responsibility and authority as Supervisor-Radiation Contro .
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There was no defined program for evaluation of professionallevel personnel qualifications relative to applicable standards. BGE selecting officials were unaware of NRC positionc relative to RPM qualification position standards published in NUREGS (e.g., NUREG/CR 5569, Revision 1, Health Physics Position Data Base).
Personnel Trainino BGE initiated very good efforts to ensure personnel were properly trained on I new procedures and procedure changes stemming from radiation protection improvement plan iterns. However, the following observations were mad BGE completed a number of program and procedure changes as a l result of problems in the area of high radiation arsa access control.
l BGE's evaluation of previous training (as a result of NRC questioning)
Identified that all appropriate iridividuals (e.g., all shift qualified rudiation safety personnel) were not trained on applicable High Radiation Area procedure changes made (e.g., Emergency Airlock door issues) following various high radiation araa access control events in early/mid 1997. This was considered a training program weaknes Individual qualifications, for those individuals noted not to have received applicable training, were temporarily downgraded by BGE pending trainin BGE initiated actions to review and evaluate all applicable recent training provide in this area and provide additional training as appropriate, Conclusiong 3GE initiated very good efforts to ensure pursonnel were properly trained on new procedures and procedure changes stemming from radiation protection improvement plan items. However, weaknesses were identified in training and qualification of newly appointed professional level personnel, including the Radiation Protection Manager, in addition, all appropriato e..dividuals did not receive training on revised procedure R7 Quality Assurance in RP&C Activities a. . 3 Code The inspector reviewed BG^~s efforts to review, evaluate, and upgrade the radiation protection program followin : the Unit 2 spent fuel pool diving event and a series of high radiation area access control events that occurred in early/mid 199 _
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b. Observations and cindinas BGE has taken action to review, evaluate, and upgrade the radiation protection program. The following initiatives were note '
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BGE conducted an independent assessment of the radiation protection program in September 1997. Industry personnel were used as independent assessors. Offsite Safety Review Committee personnel provided training following the assessment. Also, industry radiation safety personnel were used to support a June 1997 Nuclear Performance Audi BGE ina;Ld development of a Radiation Protection Improvement Plan and initlated a corrective action program to address the programmatic concerns q
identifie BGE issued a series of Plant Daficiency Reports (97-07,97-099,9711) and other corrective action initiatives in light of radiation protection program concerns note l BGE issued additional corrective action documents (RCAR (97-04)) to specifically address weaknesses in control and oversight of diving activitie As a result of dry run of enhanced procedures for diving, BGE delayed diving activities and initiated a scries of procedure and program changes to improve control and oversight of diving activitie BGE established a Site Radiation Protection Improvement Plan and team. BGE r
was developing a comprehensive radiation protection improvement plan with corrective action centered in four focus areas - organization, training, self-assessment, and procedure BGE implemented corrective actions as outlined in its September 11,1997, latter to the NR BGE initiated actions to develop a separate procedure for infrequently performed activities and initiated actions to develop and issue a new procedure for job covera 9e in radiologically controlled area BGE initiated development of a radiation safety procedure upgrade plan. The initiative included efforts to eliminate memoranda and other type documents that supplemented formally established procedure S
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The following observation was mad l
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Program procedures identified various supervoors who were to take action upon identification of issues / concerns to them (e.g., identification of intake via whole body counting). However, ne subsequent programmatic guidance was provided to ensure that the issue / concern was appropriately reviewed, evaluated, and resolved, Conclusion BGE has initiated comprehensive actions to improve the radiation protection program at Calvert Cliffs. Strong management support and involvement were noted in this effor R8 Miscellaneous RP&C lasues R8.1 UFSAR Conformance A recent discovery of a licensee operating their f acility in a manner contrwy to the UFSAR description highlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR description. While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspecte The following observation was mad BGE Technical Specification 6.3 requires that the " Radiation Safety Engineer" meet Regulatory Guide 1.8 qualification requirements. The inspector j obser/ed that no such position existed at the station and no such position was described in the UFSA BGE indicated that the position was meant to refer to the Radiation Protection Manager specified in the Regulatory Guide and that the General Supervisor Radiation Safety was to be the designated RPM. The licensee initiated a change to the UFSAR to describe the position and indicated that formal action would be taken to update the UFSAR and Technical Specificetions, as appropriat R8.2 (Closed) Unresolved item (50 317&318/97-0213) Review air sampling and analysis progra This matter is discussed in Section R3.1 of this repor R8.3 Follow-up to NRC Inspection Report and Notice of Violation dated August 11,1997 During the inspection, the inspector selectively reviewed BGE's progress in addressing violat%ns identified in the referenced inspection report. Tno inspector's
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review indic, d BGE was implementing the corrective and preventive actions outlined in its September 11,1997, letter to the NRC. The following items wore selectively reviewed. Licensee corrective actions are discussed in Section R7 of this repor &318/97 0214, Failure to implement corrective actions to identified deficiencies in high radiation area acces &318/97 0215, Failure to provide instructions for a diver in a radiologically control are &318/97-0216, Failure to control access to a very high radiation are ;
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50 317&318/97-0217, Failure to complete radiological surveys pr;or to i personnel entr R8.4 (Update) Violation (50 317&318/97 06-04)
Failure to develop and implement a procedure for control of laundered contaminated clothin The inspector's review of this riatter is discussed in Section R1.2 of this repor R8.5 Housekeeping The inspector noted that overall housekeeping was goo Manaaement Meetinga X1 Exit Meeting Summary During this inspection, periodic meetings were held witn station management to discuss inspection observations and findings. On December 29,1997, an exit meeting was held to summarize the conclusions of the inspection. BGE management in attendance acknowledged the findings presente X2 Review of UFSAR Commitments While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the Updated Final Safety Analysis (UFSAR) that related to the areas inspected to verify that the UFSAR wording was consistent with the observed plant practices, procedures and/or parameters. One issue regarding a discrepancy with a position title was described in Section R8.1 no other discrepancies were identified.
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X3 Management Meeting On November 13,1997, a management meeting was held at Calvert Cliffs Nuclear Power Plant. The public meeting included senior BGE and NRC Region I management and was held to discuss corrective actions being taken by BGE in response to an event described in NRC Inspection report 50 317&318/97 02, where a diver in the spent fuel pool was in the vicinity of very high radiation levels. -
A copy of the slides used by BGE during the meeting are included as Attachment 2 to this report.
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ATTACHMENT 1 PARTIAL LIST _ OF PERSONS CONTACTED
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SQE 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 L. Gibbs, Director, Nuclear Security -
- -T. Sydnor, General Supervisor, Plant Engineering
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T. Forgette, Director Emergency Preparedness M. Tonacci, Chemistry Supervisor G. Barley, Senior Chemist R. C. Gradle, Compilance Engineer Nuclear Regulatory Matters
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W. Paulhardt, Radiation Safety Supervisor Dosimetry L M. Rigsby, Supervisor Radiation Technical Services
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R. Wyvill, Supervisor Radiation Control P. Jones, ALARA Supervisor NBC L. Nicholson, Deputy Director, Division of Reactur Safety, Region l J. White, Chief, Radiation Safety Branch, DRS, Region I L. Doorflein, Chief, Reactor Projects Branch 1, DRP, Region 1 -
S. Bajwa, Director, Project Directorate 12, NRR A. Dromerick, Senior Project Manager, Calvert Cliffs,-NRR INSPECTION PROCEDURES USED tP 62707: Maintenance Observation IP 71707: Plant Operations -
IP 61726: Surveillance Observations IP 37550: Engineering -
IP 37551: Onsite Engineering -
IP 71750: Plant Support Activities IP 83750 Occupational Exposure
. IP 92700: Follow up of Written Reports of Events at Power Reactor F6cilities IP 92901: Follow up Plant Operations IP 92903: Follow-up Engineering
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ITEMS OPENED. CLOSED AND DISCUSSED Ooened 50 317&318/97 07-01 NCV - Testing for the emergency diesel generators did not l meet Technical Specification 4.8.1.1.2.d &318/b7 07-02 VIO Radiation Safety Procedures required by Technical Specification 6.4.1 were not adequately implemented 50 318/97 07 03
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NCV Failure to meet containment purge valve isolation Technical Specification 3.9.9 I Closed 50 317&318/97-002 LER Testing for the emergency diesel generators did not meet Technical Specification 4.8.1.1.2.d. &318/97 07 01 NCV Testing for the emergency diesel generators did not meet Technical Specificatior 4.8.1.1.2.d. /97 002 LER Containment Purge Valve isolation 50-317&318/97 001 LER Spen? Fuel Moves with Ventilatloa Inoperable 50 317&318/97 003 LER Spent Fuel Moves without Charcoal Filters 50 318/97-001 LER Refueling Machine Overload Circuit inoperable 50 317&318/96-06-03 URI Corrective Actions for Fouting of Service Water Heat Exchangers 50 31"r/96 001 LER SRW Heat Exchanger Microfouling Higher than Assumed in Design Basis 50 317&318/94 80-01 URI SRW HX Transient Analysis 50 317&318/94 80-03 URI Develop Continuing SW HX Retest Program 50 318/97-07 03 NCV Failure to ineet containment purge valve isolation Technical Specification 3. &318/97-02 13 UNR Review air sampling and analysis progra Uodated 50 317&318/97 02 14 eel Failure to implement corrective actions to identified deficiencies in high radiation area acces &318/97 02 15 eel Failure to provide instructions for a diver in a radiologically control are &318/97-02 16 eel Failure to control access to a very high radiation are &318/97-02 17 eel Fallure to complete radiological surveys prior to personnsi entr &318/97 06-04 VIO Failure to develop and implement a procedure for control of laundered contaminated clothin LIST OF ACRONYMS USED AOP Abnormal Operating Procedure
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EOP Emergency Op3 rating Procedure GL Generic Letter IR inspection Report r
LCO Limiting Condition for Operation (Technical specification)
i LE Licensee Event Report NCV Noncited Violation PDR- Public Document Room PEG Plant Engineering Guideline POSRC Plant Operations & Safety Review Committee SRW Service Wate GSM Side Stream Monitor SW Saltwater S W O P! NRC Service Water Operational Performance inspection SWP BGE Special (radiation) Work Permit
SWSOP Salt Water System Operational Performance Program TS Technical Specification UFSAR Updated Final Safety Analysis Report
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l.; Radiation Protection Improvement ,
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Agenda :
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Opening Remarks Cruse
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Dive Event Corrective Actions Katz
- NPAD Assessment Katz
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(: Site Radiation Protection Improvement Katz
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Dive Corrective Actions l
Unclear Overall Control & Leadership
- Maintenance section ownership
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- Consolidation of procedures j-
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- Industry experience
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Maintenance Oversight l l
j - Created maintenance infrequently l performed test or evolution (ITOE)
- - Activity manager Failure to Follow Procedures
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- Clarified roles and responsibilities
- Physical barrier .
- Stop work condition
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- Inadequate Communication Methods
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- Pre job brief requirements
- Single point ownership
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NPAD's Radiation Protection Program Assessment Organization and Administration:
-Roles and responsibilities for radiological work not established, communicated and internalized Procedure Adequacy and Use:
-Many Radiation Safety Procedures are difficult to use and do not control Radiation Safety Technician (RST)
l activities-Success was governed by RST knowledge l
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Self Assessment:
l -Results not effectively used to prevent or mitigate l events
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Site Radiation Protection Performance Improvement ManagementExpectations Leadership, Accountability
- Strengthen Line Ownership
- Job Proficiencies !
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- Leadership Conference
- Performance Through People !
- Personnel Changes
- Dry Run Assessment
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ALARA O RPOC Site Communication
- Personnel Safety = Radiation Safety + Industrial Safety
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Integrate Radiation Protection
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o Site Standard for Pre-job Briefs
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o Procedure Improvements
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Site Radiation Protection Performance Improvement Improve WorkerKnowledge l
- Management / Supervisor Training
- Top Down Training
- "GOT Mock-up .
- RCA Entry Improvement o Access Control Workstation Changes o Radiation. Worker Training
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Site Radiation Protection Performance Improvement ImproveEffectiveness, Follow Up
- Additional Self Assessments
'TraditionalIndicators Define for Site: Self Assessment Expectations
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Interim Actions
- Supervisor Changes in Rad Control and ALARA
- Supervisor Assist
- Increased Coverage i
- Incorporation of Job Coverage Standards and l
' Rad Con Guidelines
- Infrequent Tests or Evolutions
- ALARA Planner .
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Independent Assessrnent
- Develop a Single Overall Plan to Address Needed Improvement in Radiation Safety
- Expand Station Radiation Safety Program Indicators to Include Quality of Program Implementation !
- Establish a Multi-disciplined Site Team to Review and LRevise Radiation Protection Procedures
- Review Issue Report and Post-job Feedback Programs
- Develop a Site Standard for Pre-job Briefings
- Place High Priority on Consistent Implementation of
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RST Job Coverage Standards i
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