IR 05000317/1998006

From kanterella
Revision as of 21:22, 21 February 2021 by StriderTol (talk | contribs) (StriderTol Bot insert)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
Insp Repts 50-317/98-06 & 50-318/98-06 on 980419-0530.No Violations Noted.Major Areas Inspected:Plant Operations, Maint,Engineering & Plant Support
ML20236H118
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 06/29/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236H113 List:
References
50-317-98-06, 50-317-98-6, 50-318-98-06, 50-318-98-6, NUDOCS 9807070089
Download: ML20236H118 (14)


Text

_ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - - _ _ _ _ _ _ _

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

License No DPR-53/DPR-69 Report No /98-06 & 50-318/98-06 Licensee: Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203 Facility: Calvert Cliffs Nuclear Power Plant Units 1 and 2 Location: Lusby, Maryland Dates: April 19,1998 through May 30,1998 j inspectors: J. Scott Stewart, Senior Resident inspector Fred L. Bower lil, Resident inspector ,

Henry K. Lathrop, Resident inspector Suresh Chaudhary, Senior Reactor Engineer, DRS Tim Hoeg, Resident inspector Approved by: Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects

!

l

"

9807070009 990629 PDR ADOCK 05000317 G PDR [,_

i

.

- _ _ - - _ _ _ _ _ _ _ _ - - _ _

- _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ .

.

..

EXECUTIVE SUMMARY Calvert Cliffs Nuclear Power Plant, Units 1 and 2

, inspection Report Nos. 50-317/98-06and 50-318/98-06 This integrated inspection report includes aspects of BGE operations, maintenance, engineering and plant support. The report covers a six week period of resident inspectio Plant Operations The inspectors found the conduct of operations on both units to be very good. Fuel was reloaded into the Unit 1 reactor without problems following a ten year inservice inspection of the reactor vessel and internals. Throughout a subsequent reduced inventory period on Unit 1, BGE limited work that could affect essential core cooling systems, including work in the switchyard and other electric power supplies. The reduced inventory evolution was completed without problems and with a high regard for reactor safet The performance of a nuclear plant operator during an auxiliary building tour was good with a proper focus on equipment status and plant conditions. Communications between the plant operator and the control room were formal and complet Maintenance The Unit 1 core support barrel was lifted and removed from the reactor vessel without complication. The evolution was conducted in a well controlled manner with very good radiological controls and maintenance department coordination. The inspector found the corresponding BGE maintenance rule activities for the reactor coolant system to be appropriat Enaineerina The Unit 1 inservice inspection program was well planned and implemented. The steam l generator inspection and pressurizer heater sleeve inspection and repair were completed in  ;

a well controlled manner with an emphasis on safety. A flaw indication on the reactor l pressura vessel was dispositioned in accordance with industry standards. In all activities, j BGE engineering provided very good support, including disposition of inspection i indication j 1  !

Plant Suncort j BGE properly implemented the work stipulations specified in sections A.1, A.2, and A.3 of j the NRC Confirmatory Action Letter issued in response to radiological protection problem The inspectors observed that BGE was successful in separating planning activities from pre-job briefings. Additionally, BGE effectively communicated radiation safety expectations and assured compliance of field personnel by direct supervisory oversight. BGE plant assessment personnel were observed providing independent oversight of the pre-job planning and briefing meetings.

!

i-l ii

_ _ _ _ _ _ _ _ - _ - - _ _

-- _ _ _ _ _ _ _ -

..

l

..

!

'

TABLE OF CONTENTS

!

! EX EC UTIVE SU M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii 1 \

l TA B LE O F C O NT ENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l

l Summary of Plant Statu s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. O p e ra tio n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments (71707) ...........................1 01.2 Observation of Auxiliary Building Operator . . . . . . . . . . . . . . . . . 1 ( 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 08.1 (Closed) LER 5 0-318 \9 6-00 5 . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 11. M a i nt e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

! M1 Conduct of Maintena nce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

!

M1.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . 4

111. Engi n e e ri ng . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 '

E2 Engineering Support of Facilities and Equipment .................. 4 E Temporary Repair of ASME Code Class 3 Saltwater Piping . . . . . . 4 l E2.2 Inservice Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

,

l I V. Pl a nt S u p p ort . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 l

R8 Miscellaneous Radiation Protection and Control (RP&C) Issues . . . . . . . . 8 i R8.1 Work Observations (Confirmatory Action Letter items A.1, A.2, l

and A.3) ......................................... 8 l V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 l X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 X2 Ot he r Me eting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 l

-

ATTACHMENTS i Attachment 1 - Partial List of Persons Contacted-Inspection Procedures Used-Items Opened, Closed, and Discussed

- List of Acronyms Used

.

i

!

l l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _

_ - - _ - _ _ _ _ _ - _ _ _ - - _ _

r .

..

1'

Report Details Summarv of Plant Status

l Unit 1 was shutdown in a refueling outage and' Unit 2 operated at full power throughout
the entire inspection perio . Operations l

01 Conduct of Operations

'01.1 General Comments (71707) -

i Plant operations were conducted with a proper focus on nuclear safety. The I inspectors verified during daily control room observations that operators remained attentive and responsive to plant conditions. On Unit 1, the inspectors. verified that operations personnel properly conducted refueling activities, including assurance

. that the source range nuclear instrumentation was operating, communications

.between the control room and refueling areas were maintained, ali control rods were inserted except as permitted by the Technical Specifications (TS) for maintenance or testing, and minimum reactor vessel and spent fuel pool levels were maintaine The fuel was reloaded without problems. The inspectors found the conduct of operations on both units to be very goo The inspectors observed the BGE preparations and conduct of reactor coolant system reduced inventory activities for Unit 1 steam generator nozzle dam removal and reactor coolant pump impeller replacement. The reduced inventory activities were conducted in accordance with operations procedures which included

' contingency plans to minimize operational risk. A high level of BGE management attention was provided during the evolution. Throughout the reduced inventory period, BGE limited work that could affect essential core cooling systems, including l work in the switchyard and other electric power supplies. The reduced inventory evolution was completed without problems and with a high regard for reactor safet The inspectors _ reviewed the documented highlights of an assessment of operations activities conducted by an Institute of Nuclear Power Operations (INPO) inspection team. No plant or. system operability concerns were identified and the findings were I

. generally consistent with the NRC assessment for the review perio .2 ' Observation of Auxiliary Building Operator Inspection Scope (71707)

l

~

The inspectors observed and assessed a non-licensed equipment operator L performing a daily morning tour of the Unit 2 Auxiliary Buildin ,

i l

,

.i

_ - _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ - _ _ - _ _ _ - _ - _ - _ - _ _ _ - _ _ _ _ - _ - __- -- _ - - _ - _ - _ _ _ _ _ _ _ -

.

.

2 Observations and Firidinas The non-licensed operator attended the morning shift turnover where equipment operating status, major work in progress, and plant problems were reviewed. The operator was attentive and demonstrated an understanding of equipment and plant status. The operator was knowledgeable in the performance of assigned tasks and wore the required safety equipment while touring plant areas. All assigned areas were visited and plant parameters were electronically logged using a hand held data storage device. Local strip chart recorders were verified to be functioning properly and were initiated and dated by the operator in accordance with BGE management expectations. The operator observed Special Work Permit requirements and all other signs and postings during entry and exit from the various rooms and areas in the radiologically controlled area. Communications between the operator and the control room were formal and complet Conclusions The performance of a nuclear plant operator performance during an auxiliary building tour was good with a proper focus on equipment status and observation of plant conditions. Communications between the plant operator and the control room were formal and complet Miscellaneous Operations !ssuss 08.1 '(Closed) LER 50-318\96-005: Reactor Trip Due to Closure of'Feedwater Regulating ,

Valve. A Unit 2 reactor trip occurred when a spring retainer failed in the controls i for a feedwater regulating valve. The reactor trip, immediate corrective actions, and plant recovery were inspected and reported in NRC Inspection Report 50-317&318/96-08. The inspectors previously verified that the spring retainers for Unit 1 feedwater regulating valves were inspected during the reactor coolant pump i seal replacement outage in September 1997. During the current Unit 1 refueling )

outage, the inspectors were informed by plant engineering that the feedwater regulating valve positioners were replaced with a new design that did not use a spring. The positioner will be installed on Unit 2 in the 1999 outage. The LER is close . Maintenance M1 Conduct of Maintenance i M1.1 General Comments Inspection Scope (62707)

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

_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

.. -_-__ - - -. - _ _ - - - _ - _ _ - - _ - - - _ _ -

. i l

...

program were assessed to determine if the maintenance was effective. Also, the inspectors'directly observed all or portions of the following work activities:

[ ,

MO2199801530 ' Install Bandit Clamp on CCW HX Inlet Saltwater Piping MO1199800890 ' Removal of Core Support Barrel MO1199705201 Saltwater Piping Replacement (- Observations and Findinas L The inspectors observed removal of the Unit 1 core support barrel to support a ten  ;

L' year reactor vessel inservice inspection. The removal activity was considered an '

l : infrequent maintenance activity and a radiologically high risk job. These l designations required formal pre-job briefings by' maintenance supervision that included both operational and radiological risk discussions and a discussion of assigned responsibilities for each participating individual. A detailed radiological assessment including an ALARA review'was completed and discussed with the participants. The planning included contingencies for expected and possible

! problems including actions to be taken should damage to the refueling pool occu An appropriate level of management oversight was evident during the evolution.

t,

- The core support barrel was part of the reactor coolant system in the BGE i maintenance rule program. The system had been designated A(1) due to a L

'

functional failure of a compression fitting on Unit 1 in 1997. Following the 1997 failure, an inspection of Unit 1 compression fittings was conducted. An 10 CFR l - 50.65 A(1) goal for the system had been established; that being no failures of instrument tubing compression fittings for the remainder of the Unit 1 operating cycle. This goal was met when the unit was shutdown in April and an inspection was conducted to ide'ntify if any compression fittings had failed. The insp'ector verified that this activity had been completed and no. failures were identified. Also, a BGE quality assurance audit of compression fitting work during the outage was in

- progress during the inspection perio Conclusions -

The_ Unit 1 core support barrel was lifted and removed from the reactor vessel without complication. ' The evolution was conducted in a well controlled manner with very good radiological protection and maintenance department coordinatio The inspector found the corresponding BGE maintenance rule activities for the reactor coolant system to be appropriate.

U l

,

l

!'

_ _ _ _ _ _ . _ _ _ _ _ _ _ _ - - _ . _ - _ _ - _ - _ - _ _ _ _ - _ _ _ - - - _ _ _ _ - _ _ _ _

_ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - __ _ _ - - _ _ _ _ _ - - _ _ __ _ _ _____ _ _ _

.

..-

-M1.2 Routine Surveillance Observations a .' inspection Scone (61726)

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

I STP-O-73D-1' Charging Pump Performance Test STP-O-5A-2 . Auxiliary Feedwater System Quarterly Surveillance Test STP-O-4A 1. "A" Train Integrated Engineered Safety Features Test STP-O-5-2 Auxiliary Feedwater System Monthly Surveillance Test m- Observations and Findinas The inspectors found that the selected surveillance activities were performed safely and in accordance with approved procedures. Test details were discussed at a pre-r test briefing followed by a question and answer session. The session was attended

' by all test participants and included clearly stated test expectations. The test

, participants were knowledgeable of their assigned responsibilities. Supervision and L - system engineering participated in the pre-test briefings and test conduc c.: Conclusions The surveillance testing performed during this inspection period was completed in a well controlled manner in accordance with clearly stated expectations. Appropriate plant supervision and system engineers provided active oversight and monitoring during the testin Ill. Engineering E2 Engineering Support of Facilities and Equipment E2.1 Temporary Repair of ASME Code Class 3 Saltwater Piping Scope  !

The inspectors reviewed BGE corrective actions for a through-wallleak at a  !

'

. temperature instrument well weld in the 21 component cooling heat exchanger  ;

saltwater inlet pipin Observations and Findinas

,

On May 25, BGE identified saltwater leaking from the 21 component cooling heat exchanger saltwater piping. The leak ~was through an approximately 1/16th inch diameter hole in a weld for an instrument tap on the piping. BGE entered the

. appropriate technical specification action statements associated with the 21 component cooling water loop being out of service and for the structural integrity of saltwater piping'not meeting ASME Code Class 3 requirements. Discussions with l

BGE personnel indicated that a temporary non-code repair was planned to return the

- - _ _ _ _ _ _ _ - _ . ___________-__ - _- a

___-_______ _________ - _ _ _ -_____ _ _ - _ _ _ _ - _ _ _ _ _ _ _ - -

e ,

?'

f~

/

l

,

system to service before tiw expir::tien of the allowed outage time. The inspectors

'

questioned whether an operability determination had been perfonned and whether a

!

relief request for the non-code repair would be submitted to the NRC for approva Discussions with system engineering personnelindicated that an operability

'

determination was under development.

i L

' A relief request was discussed in a telephone conference call between BGE and

"

NRC Headquarters, the Region I office, and the resident inspector staffs on May 26. By letter dated May 27, BGE submitted a relief request for NRC revie .The inspectors reviewed the operability determination performed by BGE engineering and concluded that the condition would not impact nuclear safety or operatio BGE stated in the determination that a catastrophic failure of the branch connection

, would be bounded by a previously completed flooding analysis. Additionally, BGE

[: performed an analysis that determined that margin existed to ensure adequate p saltwater flow to the component cooling heat exchanger in event of the weld H

failure. The inspectors determined that the operability determination was appropriate in scope and detail. BGE submitted a relief request as specified by NRC

4 Generic Letters 91-1B, "Information to Licensees Regarding NRC Inspection Manual (. Sections on Resolution of Degraded and Nonconforming Conditions and on Operability" and 90-05, " Guidance for Performing Temporary Non-Code Repair of

, ASME Code Class 1,2, and 3 Piping".

h . Conclusions BGE identified a through-wall leak in a weld in the inlet piping to the 21 component cooling heat exchanger and entered the appropriate technical specification action statements. The BGE operability determination for returning the 21 component j' cooling heat exchanger to service with a temporary non-code repair installed was appropriate in scope and detai E2.2 Inservice inspection

- . Insoection Scooe (73753)

L l

An inspection was performed to confirm that the inservice inspection (ISI), repair, L

, and replacement of Class 1,2, and 3 pressure retaining components were performed in accordance with the Technical Specifications (TS), the applicable ASME Code, NRC requirements, and industry initiatives, including any relief requests granted by the NR The scope of the inspection included the review of the BGE ISI program procedures,-

qualification of inspection / examination personnel, schedule of planned ISls for the current refueling outage, and observation of ISI wor .

,.

_ - _ _ _ _ . _ _ _ - _ . . . _ - - - - _ - _ _ _ _ . _ _ _ _ - - - - _ - -

__ _--- _ - _ _ _ - - _ - _ - _ _ _ - _ _ _ - - - - - -

.

.

6 Observation and Findinos The second ten-year Interval for the Calvert Cliffs Nuclear Power Plant inservice inspection (ISI) began on April 1,1987, for both units. The ISl plan had been developed in accordance with the NRC regulatory requirements,Section XI of the ASME Code, the plant Technical Specifications, and the RG 1.147 approved code cases. Accordingly, the ISI plan provided the necessary details for planned ISI of Code Classes 1,2, and 3 pressure retaining components and supports. The ten year interval was divided into three periods. The current period was the last of this interva Procedures and Personnel The inspector reviewed the nondestructive examination procedures used by BGE and found the procedures clearly written and contained adequate explanation of the technical basis and work control. Additionally, the inspector reviewed approximately eight data reports (two each from UT, MT, PT, & VT) and determined that examination results, evaluation results, and corrective action, if any, were properly recorded as specified in the ISI program. The documentation of the examination and evaluations were appropriat The review of the qualification / certification of the personnel engaged in the NDE of the ISI program indicated that the inspectors were properly qualified by formal and practical training, and were certified to proper levels of inspection / examination responsibility in the different examination methods; e.g., visual examination (VT),

liquid penetrant (PT), magnetic particle (MT), or ultrasonic examination (UT). BGE engaged a contractor to perform the remote internal examination of steam generators, and provide most of the eddy current examiners and analysts for the Unit 1 steam generator tube inspection There were four BGE inspectors, and seven contractor inspectors engaged in ISI work. The qualification and certification of the VT-inspectors were in accordance with the requirements of SNT-TC-1 A, as mandated by ANSI /ASME N45.2.6-1978, which was accepted by Code case N-424. All other personnel, except eddy current test analysts, were qualified / certified in accordance with the requirements of the Code. The eddy current test (ECT) analysts were qualified and certified according to BGE procedure MN-3-105," Qualification of NDE Personnel and Procedures,"

which required that personnel analyzing steam generator (SG) eddy-current data be certified in accordance with the current revision of EPRI TR-106589,PWR Steam Generator Examination Guidelines, Appendix G (commonly referred to as QDA)

documen _ _ _ _ _ _ _ t

-__ _ _ _ - _-___ _ _ _ _ - _ _ _ _ _ _ _ _ . .

.

.

Pressurizer Heater Replacement The BGE inspection of the pressurizer heaters during the current outage disclosed evidence of leakage at heater location B-12 from an internal pressure boundary weld. BGE determined that the leakage was the result of post-weld stress corrosion cracking and decided to repair the leak by removal of the heater, partial removal of the sleeve, and plugging and welding the openin The inspector reviewed the Engineering Service Package No. ES-199800559and verified that the package contained an extensive safety evaluation (50.59), and the modification plan. The package also included an evaluation of the licensing basis of the pressurizer heater and the heater capacity study for Unit 1. Also, the inspector visually examined the heater location, and witnessed the data gathering for the plug installation. The BGE identification, analysis, evaluation, and planning and control of the repair operation were handled wel Pioe Replacement in the Saltwater System The inspector verified that the BGE Replacement Plan No. 98-1-206 (Maintenance Work Order No. 1199705201)was properly implemented. The replacement

'

involved fabricating new spool pieces for above ground saltwater piping syste The inspector witnessed the welding operations for the spool in the maintenance -

fabrication shop and observed that the fabrication procedures for control of welding process and material, and conformance to the drawing and design were effectively !

implemented. The fabrication process was acceptabl I Edv Current Examinations of Steam Generator Tubes I

BGE contracted a vendor to acquire and analyze eddy current test (ECT) data for the )

Unit 1 steam generators. The vendor's procedures used for data acquisition and analysis were reviewed and approved by BGE. The inspection method consisted of bobbin coil and rotating coil inspections. The inspector witnessed the remote data gathering and plugging of ten hot leg tubes in a steam generator and reviewed the documented analysis activitie The ECT procedure provided for an independent review of the eddy current dat ,

This independent review was performed by a separate and independent contractor !

(Zetec).

, Based on the steam generator inspection,114 tubes in SG 11 steam generator and 169 tubes in SG 12 were removed from service by plugging. This made a total of 604 tubes plugged (7.1 %)in 11 steam generator and 776 tubes plugged (9.1 %)in SG 12. Both steam generators were Category C-3 according to Technical Specification 3.4.5, due to greater than one percent defective tubes identified during the inspection. In accordance with the technical specifications, BGE notified

'

the NRC Region i NRC Administrator of the results on May 13,1998.

l

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ __-____-_ ____-____ _ _____ __ _ _-__________ ______-_______ _-_

.

.

The inspector's review of the BGE data package of the SG examinations did not identify any unacceptable items. BGE was finalizing the final data package for submittal to the NR Reactor Pressure Vessel (RPV) Weld 1-203-C The planned ten year RPV ISI during this outage detected an outside diameter (OD)

surface connected indication. The flaw was located approximately 70 inches below the reactor .essel flange and had a depth from outside surf ace of 0.38". The indicated flaw length was 2.88" resulting in an aspect ratio of 0.13. Since the flaw was parallel to the vessel wall, it was not apparent if it was on the surface or in the wall. As measured from the inside of the vessel, the flaw size exceeded the acceptance standard of the ASME Code,Section XI, Table IWB-2500- BGE performed a preliminary evaluation of the indication in accordance with the ASME Code 1989,Section XI, Appendix A, and IWB 3600, which determined that the flaw size, including margin for future growth, was acceptable. BGE completed a visual and non-destructive examination from the reactor vessel external surfac From this view, which was closer to the actual flaw location, the flaw was found to be two separate weld slag stringers which were within code acceptance standard c. Conclusions The Unit 1 inservice inspection program was well planned and implemented. The steam generator inspection and pressurizer heater sleeve inspection and repair were completed in a well controlled manner with an emphasis on safety. A flaw indication on the reactor pressure vessel was dispositioned in accordance with industry standards. In all activities, BGE engineering provided very good support, including disposition of inspection indication IV. Plant Support R8 Miscellaneous Radiological Protection and Chemistry (RP&C) Issues i

R8.1 Work Observations (Confirmatory Action Letter items A.1, A.2, and A.3) I a. Inspection Scope l

The inspectors reviewed / verified / determined BGE compliance with items A.1 and l A.2 of the NRC Confirmatory Action Letter (CAL) sent to BGE on April 29,199 The CAL responded to radiological controls events that occurred on April 9,199 Additionally, the inspectors checked that BGE Nuclear Plant Assessment

, Department personnel observed some portions of higher risk radiological activities in accordance with Confirmatory Action Letter item \

l l

r

'

I i

_ _ _ _ _ _ _ -

- _ _ __ _-___-_ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _

... ,

b.' - Findinas and Observations

.BGE implemented radiation protection control and protective measures as described in the BGE April .27,1998 letter to the NRC and the Confirmatory Action Lette During selected activities, the inspectors verified that department supervision from both maintenance (the task) and radiation. protection departments provided oversight of the pre-job planning, attended the pre-job briefings, and provided direct-

. oversight of field work in radiation areas. BGE Nuclear Plant Assessment Department (NPAD) personnel were observed providing oversight during pre-job ,

planning and briefing meetings. In these cases, the supervision provided assurance

. that radiation safety controls were effectively communicated to the personnel responsible for conduct and control of the work activities by directly conducting the briefings and reviewing requirements with the workers. - Additionally, the supervisory personnel who conducted the briefings provided direct oversight of the field activities whenever actual work was being performe Portions of the.following higher radiological risk activities were inspected:

Reactor core barrel removal on April 24; Removal of 11 A and 128 reactor coolant pump seals on May 4;

. . Planning and preparations for nozzle dam removal on May 21; Performance of Upper Guide Structure lift rig destruction on May 22; Removal of reactor coolant pump impellers on May 7;

^

Performance of reactor coolant pump casing measurements on May 7; 4 ' Pressurizer sleeve inspection and repair on May 7;

"

Refueling pool liner inspection on May 7; and

,

Reactor Vessel Annulus 1-203-C Weld Inspection on May 27.

,

Following an investigation by BGE of the April 9 radiological controls problems, BGE l= specified training for all site personnel on the events. The inspectors attended a number of training sessions for all BGE employees and contractors involved in i- radiological work. The training summarized the April 9 events and discussed L management expectations for conduct of radiological work. These expectations included careful review and compliance with Special Work Permit requirements,

proper dosimetry, and reminders that workers are accountable for safety during

[

'

radiological work. The inspectors observed that BGE managers attended the t training sessions and BGE s'upervisors conducted the training.

L Conclusions-BGE properly implemented the work stipulations specified in sections A.1, A.2, and

' A.3 cf the NRC Confirmatory Action Letter. The inspectors observed that BGE was successfulin separating planning activities from pre-job briefings. Additionally, BGE l

effectively communicated radiation safety expectations and assured compliance of I

>

field personnel by direct supervisory oversight. BGE NPAD personnel were

.

observed providing independent oversight of the pre-job planning and briefing meetings.

l L_ _ __=__________---_ _

. __

. _ _ - - - - - ._ - - .

.

I

V. Manaaement Meetinas X1 Exit Meeting Summary During this inspection, periodic meetings were held with station management to discuss inspection observations and findings. On June 15,1998, an exit meeting was held to summarize the conclusions of the inspection. BGE management in attendance acknowledged the findings presente X2 Other Meetings  ;

On May 28,1998, an enforcement conference was held with BGE at the NRC Region I office to discuss the findings of NRC inspection 50-317&318/98-04 '

regarding the BGE maintenance rule program. The results of that meeting, including a copy of the material presented at the meeting, will be issued in a separate NRC correspondenc Y.

i

.'

.

I

_ _ _ _ - _ _ _ - _ _ _ _ _ _ _ - _ _ _ - _ - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - _ - - _ _ _ _ _ _ _ _ - _ _ _

.

.

ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED BGE C. Cruse, Vice President- Nuclear Energy Division P. Katz, Plant General Manager P. Chabot, Manager, Nuclear Engineering K. Cellars, Superintendent, Nuclear Maintenance K. Neitmann, Superintendent, Nuclear Operations T. Pritchett, Director, Nuclear Regulatory Matters M. Rigsby, Supervisor, Radiation Safety T. Sydnor, General Supervisor, Plant Engineering M. Navin, General Supervisor, Plant Operations INSPECTION PROCEDURES USED IP 61726: Surveillance Observations IP 62707: Maintenance Observation IP 71707: Plant Operations IP 92700: Onsite Followup of Wiitten Reports of Nonroutine Events at Power Reactor Facilities j IP 73755 Inservice Inspection - Data Review and Evaluation '

IP 37551 Onsite Engineering IP 71750 Plant Support Activities

!

ITEMS OPENED. CLOSED. AND DISCUSSED l

ClosqH;f LER 50-318/96-005 Reactor Trip Due to Closure of Feedwater Regulating Valve LIST OF ACRONYMS USED ALARA As Low As is Reasonably Achievable ASME American Society of Mechanical Engineers CAL Confirmatory Action Letter CCW Component Cooling Water CFR Code of Federal Regulations HX Heat Exchanger INPO Institute of Nuclear Power Operations ISI Inservice inspection LER Licensee Event Report MT Magnetic Particle Test NPAD Nuclear Plant Assessment Department PT Liquid Penetrant Test RP&C Radiological Protection and Chemistry

,

RPV Reactor Pressure Vessel l UT Ultrasonic Test VT Visual Test

_ - _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ . _ _ _ _ _ _