IR 05000317/1978022

IE Inspec Rept 50-317/78-22 & 50-318/78-16 on 780808-11 During Which 3 Items of Noncompliance Were Noted:Radiat Protec Procedures;Procedure CCI-607B Not Incorp Into training;NUREG-0041,Section 9.8 Procedures Ignored

ML20062C505
Person / Time
Site:	Calvert Cliffs
Issue date:	09/12/1978
From:	Knapp P, Serabian J, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20062C494	List: IR 05000317/1978022 ML20062C488 ML20062C495 ML20062C500 ML20062C504
References
50-317-78-22, 50-318-78-16, NUDOCS 7811090038
Download: ML20062C505 (11)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-317/78-22 .

Report No. 30-318/78-16 50-317 >

Docket No. 50-318 DPR-53 C License No. DPR-69 Priority --

Category C

! Licensee: Baltimore Gas and Electric Company

P. O. Box 1475 Baltimore, Maryland 21203

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Facility Name: Calvert Cliffs Units 1 & 2 '

Inspection at: Lusby, Maryland ,

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Inspection conducted: going 1,1978 Znspectors: Md J. R4 White, RaJiation Specialist 9 7

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J. g. Serabian, Radiation Specialist (Intern) date signed N '

date signed Approved by: Muu N te m 9 -12 -7 8 P. Mapp, Cliief \\' date signed Radiation Support Section Ensoection Summary:

Insoection on August 8-11, 1978 (Report No. 50-317/78-22; 50-318/78-16}

Areas Inpsected: Routine, unannounced inspection by regional based inspectors of the radiation protection program during normal operations including: .

exposure control; training; qualiff' cations; radiological protection procedures; posting and control; instruments and equipment; respiratory protection program; neutron monitoring; and inspector followup on IE Bulletin No. 78-0 On August 8,1978, the inspection conmenced during non-regular hours (7:15 p.m. to 9:30 p.m.) and involved a review of controlled areas of the plant to determine whether the radic, logical protection program was being

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effectively implemented. The inspection involved 54 inspector-hours onsite by two regional based inspectors.

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Region I Fonn 12 (Rev. April 77) 6/7f-M60 . _ - _ - - _ _ _

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Inspection Summary 2 ,

l Results: Of the nine areas inspected, three apparent items of noncompliance were found in Units 1 and 2, in the following areas (infraction - failure to follow procedures in accord with the requirements of Technical Specification 6.11 - Paragraph 6; Units 1 and 2 infraction - failure to adhere to the requiremer.ts of Technical Specification 6.4 - Paragraph 3; infraction -

failure to adhere to the requirements of 10 CFR 20.103 regarding respiratory protection - Paragraph 8).

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l DETAILS

, 1. Persons Contacted

• A. Kaupa, Radiation Safety and Chemistry Engineer

• E. Reimer, Medical Assistant J. Speciale, Foreman, Radiation Safety and Chemistry T. Logsdon, Training Specialist

• denotes those individuals attending the exit intervie Additionally, the following person also attended the exit interview:

R. Douglass, Chief Engineer The inspectors interviewed several other licensee employees, including members of the Radiation Safety and Chemistry staff, auxiliary operators, and other plant staf . Qualification of Personnel

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The inspectors examined the qualifications of radiation protection personnel pursuant to Technical Specification 6.3, " Facility Staff Qualification," which endorses ANSI standard N18.1-1971, " Standards for Selection and Training of Personnel for Nuclear Power Plants,"

for comparable positions. The records of all non-supervisory radiation protection personnel were reviewe No items of noncompliance were identifie .

3. Training

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i(' On August 9,1978, the inspectors reviewed the Rad-Chem technician i

training against Procedure CCI-6078, " Radiation Safety and Chemistry Personnel Training," and CCI-610A, " Personnel Training Records,"

developed pursuant to Technical Specification 6.4, " Training".

Technical Specification 6.4 states that the retraining end replace-ment training shall be maintained and meet or exceed the requirements and recomendations of Section 5.5 of ANSI N18.1-1971, " Standards for Selection and Training of Personnel for Nuclear Power Plants". This sectio states, "A retraining program shall be established which maintains l the proficiency of the operating organization through periodic i

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I training exercises, instruction periods, and review covering those items and equipment which relate to safe operation of th facility and through special training sessions for replacement personnel.

Means should be provided in the training programs for appropriate t evaluation of its effectiveness." In the course of reviewing

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Procedure CCI-610A, the inspector noted that provisions of Section C.2 specify a process for achieving the appropriate evaluation of training effectiveness. Section C.2. , "On-The-Job Training", ,

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requires that completed qualification cards and check-off sheets identifying the exact on-the-job training requirements be incorporated and maintained as part of the training recor ;

The inspector examined the training records of all non-supervisory

radiation protection personnel against this requirenent. It was l observed that none of the records of training given for qualifying

Radiation and Chemistry (Rad-Chem) technicians, identified the  !

exact on-the-job training requirements used for the technicians'

qualification; and thus did not provide the means necessary to  !

, demonstrate appropriate evaluation of the effectiveness of the  ;

i training given.

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The inspector noted that the on-the-job training qualification technique utilized by the licensee relied solely on the judgment

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and discretion of the Rad-Chem Foremen; without specific guidance or direction on which to base their evaluation, beyond the foremen's experienc : The inspector identified failure to establish and use specific '

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statements of on-the-job training requirements in the training system for non-supervisory radiation protection personnel as noncompliance i with the requirement for a system of evaluating training effectiveness incorporated into Technical Specification 6.4. (317/78-22-01;

318/78-16-01)  : Radiological Protection Procedures l

i The inspector reviewed procedures relating to exposure control,

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instruments and calibration, and Rad-Chem Technician and Radiation .

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Monitoring Personnel training. Procedures were reviewed against  !

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the requirements set forth in Technical Specification 6.8, " Procedures",

Regulatory Guide 1.33-1972. " Quality Assurance Program Requirements",

i Technical Specification 6.11. " Radiation Protection Program" and the applicable regulatory requirements of 10 CFR 2 ,

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i In reviewing procedure RCP-2-413 Rev. O, " Calibration and' Mainten-l ance of the Eberline PIC-6A Survey Meter," the inspector noted that .

i the calibration technique described therein necessitated performing j adjustments to the instrument while it is located in a 15 R/hr i radiation field. The inspector verified by actual measurements

that extremity exposure while making the instrument adjustment could be as high as 10 R/hr to the hands.

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! the instrument from the field to adjust) which does not involve

! extremity exposure. The inspector discussed this as a matter

! of interest with the licensee representative. .The Ticensee'

i representative' stated that action would be initiated to revise i the calibration procedure to ensure that the technique specified in j the procedure for calibration adjustment does not involve extremity 1 exposure to the individual,

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, The inspector noted that this item would be reviewed in a subsequent

inspection. (317/78-22-02;318/78-16-02)

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l Instruments and Equipment The inspector examined the licensee's calibration documents for

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adequacy. Calibration procedures were examined against procedural requirements for calibration frequency and accuracy. Calibration j stickers on 20 instruments were checked to determine whether the i

calibration frequency was being maintained as required by procedure

) RCP-2-402, Rev.1, " Calibration and Maintenance Records." The inspector noted that procedure RCP-2-402, Rev.1, states that instruments must be calibrated within the three day period ending a

with the due date shown on the " Annual Instrument Calibration

!. Record," form, RCP-2-402-4. Instruments found to be out of calibra-

I tion are to be tagged with a rejection sticker and segregated from other instruments. On August 10, 1978, the inspector observed

) instruments for which the calibration due date had been passed and i which were not tagged with a rejection sticker and which were not

segregated from other instruments available for use. These instru-

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J ments are identified in the following table.

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l Instrument Status Instrument Serial N Calibration Date Board Notation PIC-6A 1348 8/4/78 In Service PIC-6A 1342 8/4/78 In Service Teletector 2 8/1/78 In Service

(6112)

The licensee representative, upon being notified by the inspector of the three instruments found to be beyond calibration, innediately removed those instruments from their accessible locations to the instrument work benc The inspector noted thatTechnical Specification 6.11 " Radiation Protection Program" requires that procedures be prepared consistent with the requirements of 10 CFR, and be approved, maintained and adhered to for all operations involving personnel radiation exposur It was noted by the inspector that failure to adhere to the requirements specified in procedure RCP-2-402, constituted noncompliance with 1 Technical Specification 6.11. (317/78-22-03; 318/78-16-03) Respiratory Protection Program; Internal Exposure Control _ The inspector established through questioning licensee repre-  :

sentatives and reviewing records that the licensee makes allowance for the use of respiratory protective equipment in limiting the inhalation of airborne radioactive materia The inspector reviewed the licensee's respiratory protection

~ program against the following:

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10 CFR 20.103, " Exposure of individuals to concentrations

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of radioactive materials in air in restricted areas."

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-- Regulatory Guide 8.15, Acceptable Programs for Respiratory j Protectio _

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Regulatory Guide 8.15, which augments the regulatory require-ments of 10 CFR 20.103, states in Section C.8.a, " Respirable :

air of approved quality and quantity is to be provided and oxy en deficiency is to be avoided (NUREG-0041, Sections ...

9.8 ."

NUREG-0041, Section 9.8, " Maintenance of Air for Oxygen Supplies,"

requires that procedures for the maintenance of a supply of :

respirable air or oxygen are included as part of the respiratory protection equipment program; and that compressed gas cylinder supplies are to be maintained and used in accord with appropri-ate standards and recamiendation NUREG-0041, Chaptac 3, Elements of an Acceptable Program, and Chapter 5, Classification, DescrTition, and Limitations of

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Respirators, recomends the following standards regarding air supplies in compressed gas cylinders:

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ANSI Z48.1-1954, " Method of Marking Portable Compressed '

Gas Containers to Identify the Material Contained."

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Federal Specification BB-A-1034.a. " Air Canpressed for Breathing Purposes."

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Interim Federal Specification GG-B-00675.b " Breathing Apparatus, Self Contained."

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Compressed Gas Association Commodity Specification G-7.1-1966, " Commodity Specification for Air" (ANSI Z86.1-1972)

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Compressed Gas Association Specification G-7, " Compressed Air for Human Respiration." ,

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ANSI Z88.2-1969, " Standard Practices for Respiratory Protection. "

NUREG-0041 also recommends that compressed air for breathing purposes meet Grade "E" specifications; that as recommended in ANSI Z88.2-1969, Grade "D" air should be regarded as the limit for air of deteriorating qualit ,

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The inspector noted on August 11, 1978, that although the licensee utilized cylinders of compressed air for breathing purposes, and provides for the charging of such cylinders in-house, there were neither procedures for the maintenance of breathing air supplies in compressed gas cylinders, nor was there any form of quality assurance implemented to verify that the quality of air supplied was in accord with the appropriate standards and recommendations, such as those endorsed by NUREG-004 The licensee could not demonstrate that the quality of the breathing air met at least Grade "0" specifi-cation The inspector identified making allowance for the use of respiratory protective equipment in the absence of pro::edures for maintaining a respirable air supply and for verifying that breathing air quality meets appropriate standards, as noncompli-ance with 10 CFR 20.103 (317/78-22-04; 318/78-16-04) The inspector reviewed the personnel exposure records of 30 individuals against the regulatory requirements of 10 CFR 2 pertaining to internal deposition of airborne radioactivit No items of noncompliance were identifie . Posting and Control On August 8 and 10, 1978, a tour through various areas of the plant was performed to review the posting and control of radiciogical areas and radioactive material against the requirements of 10 CFR 20.105, " Permissible Levels of Radiation in Unrestricted Areas" and 10 CFR 20.203, " Caution Signs, Labels, Signals, and Controls."

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No items of noncompliance were identifie . Radiation Protection Organization During the course of the inspection, the inspector learned that the Radiation Protection Organization had changed since it was last reported in inspection 50-317/77-17; 50-318/77-15. The current Radiation Protection Organization Chart is as follows:

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Radiation Safety & Cnemistry (RS&E) Engineer Medical Assistant Performance Engineers RS&C Foreman (Chemistry) RS&C Foreman (RadiationProtection)

- I Radiochemistry Chemistry Cou'nting Dosiinetry & Waste &

Room Respiratory Laundry Protection Decon Cleaners Personnel Monitoring, Neutron The inspector reviewed the licensee's neutron n.onitoring program against the requirements of 10 CFR 20.202, " Personnel Monitoring",

and Regulatory Guide 8.14, " Personnel Neutron Dosimeters."

10 CFR 20.202 requires the licensea to supply appropriate personnel monitoring equipment (i.e., film badges, pocket chambers, pocket dosimeters, film rings, etc) and to require the use of such equipment by each individual who enterra restricted area under such circ'Jnstar.cas

that the individual receives or is likely to receive a dose in a calendar quarter in excess of 25 percent of the applicable value saecified in 10 CFR 20.10 Regarding personnel neutron monitoring equipment, the standard (ANSI N319-1976, " Standard for Personnel Neutron Dosimeters- Neutron

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energies less than 20 MeV) requires in paragraph 4.1, that such dosimetry be capable of detecting a minimum quarterly neutron dose equivalent of 300 mren (i.e. , the lower limit of detection for the I dosimetry system shall be no greater than 300 mrem divided by the !

number of dosimetry periods per quarter).

Regulatory Guide 8.14, which indicates that the ANSI N319-1976 is generally acceptable, supplements the requirenents of the standard by stating, " Neutron dosimeters should be worn whenever the neutron dose equivalent is likely to exceed 300 mrem in a quarter (the minimum sensitivity required of a neutron dosimeter in paragraph 4.1 of the standard)." In this manner, Regulatory Guide 8.14.is  !

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consistent with the regulatory requirement of 10 CFR 20.202, in that 300 mrem per i whole body value1.250 (quarter rem)isspecified approximately 25%

in 10 CFR of the 20.101 a).ap(plicable l The inspector noted that, in lieu of the usual types tif devices nomally employed for personnel monitoring, the licensee's procedure  !

(RCP-3-307, " Determination of Neutron Exposure") provided for the  !

i use of a portable neutron survey instrument (PNR-4) in detemining  !

the neutron dose equivalent to which' personnel were exposed. A l measurement of the maximum neutron dose rate to which the individual

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can be exposed is combined'with the individual's occupancy time in

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the neutron radiation area to detamine the individual's exposur (e.g., a maxNnum neutron measuricent of 200 mrem per hour in an

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area occupied by an individual for 30 minutes yields a personnel neutron exposure'of 100 mram).

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The licensee indicated to the inspector that in order to assure the .

intent of 10 CFR 20.202 was fully met, procedure RCP-3-307 would be  !

amended to require the Radiation Safety and Chemistry Engineer to personnally review ard authorize personnel exposure to neutrons when such exposure is (or is expected to be) greater than 300 mrem

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The licensee also indicated it wrs expected that the use of a personnel neutron monitoring device would be implemented by the station in approximately six months. The inspector indicated that this item would be reviewed in a subsequent inspection. (317/78-22-05; 318/78-16-05)

No items of noncompliance were identified.

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( 1 Licenses Action on Bulletins The inspector reviewed the licensee's response to IE Bulletin N l 78-07, " Protection Afforded by Air-Line Respirators and Supplied Air Hoods", as provided in the licensee's letter of July 21, 197 .

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i Regarding the licensee's use of air supplied hoods, the inspector noted that the licensee's program does not provide for the use of calibrated air flow measuring equipment as recommended by the bulle-  !

tin. The inspector noted that this item would remain open pending l j the perfomance of independent measurements on the supplied air ,

system in a subsequent inspection. (78-8U-07)

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11. Exit Interview

, The inspector met with the licensee representatives (denoted in

Paragraph 1) at the conclusion of the inspection of August 10, 1978,

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and sunnarized the scope and findings of the inspection. The licensee

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representative made the following cannents concerning items discussed

by the inspecto Procedure CCI 607B will be amended to indicate that Part A l (Fundamental Training Courses) is prerequisite to the Part B

, (On-the-job-training) in order to assure that only fully

capable personnel are qualified as Rad-Chem Technician Waivers from the Fundamental Training Courses (Part A of CCI i

607B) will be granted if deemed appropriate to the Radiation Safety &

s Chemistry Engineer, provided the basis for such waiver demon-strates that the person has the required knowledge without

] benefit of the Fundamental Training Course :

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The Radiation Safety and Chemistry Engineer w~ ~ ill provide a review and

! authorization for entry into neutron radiation areas in the

! case of individuals expected to receive greater then 300 mrem

(neutron) per calendar quarter.

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