ML20199E607
| 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) | |
See also: IR 05000317/1997007
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6.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
License Nos. DPR-53/DPR-69 l
Report Nos. 50-317/97-07
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
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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 safety.
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 appropriately.
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.
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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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documented.
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
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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 deficiencies.
Enaineerina
BGE had implemented an effective saltwater performance monitoring program in 1994.
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 exchangers.
, 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
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Executive Summery (cont'd)
inspectors considered th'a potential for changing fouling factors and fouling rates will
require continued BGE attention.
Plant Support
in general, radiological controls were appropriately implemented. Special work permit
(SWP) and survey maps reflected protective measures and area conditions, respectively.
Areas were found to be generally clean and well maintained. Workers were fcund to
knowledgeable of the required radiological controls.
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 requirements.
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.
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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 issue.
BGE implemented a generally effective external and internal dosimetry programs.
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
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08.4 (Closed) LER 50-317&318/97-003 . . . . . . . . . . . . . . . . . . . . . .6
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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
E2.1 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
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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
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M anagement Mee tings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
X2 Review of UFSAR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
X3 Management Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 5
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] 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
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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
period.
01 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 conditions. 1
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 room.
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 circumstances. ,
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
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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 appropriate.
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 times.
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02 Operational Status of Facilities and Equipment
02.1 - Safety Tagging (71707)
- a. 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).
b. 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
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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 required.
c.- Conclusions
The inspectors concluded that the safety tagging clearances reviewed were
prepared, authorized, hung, and removed properly.
02.2 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 necessary.
0.7 Quality Assurance in Operations
07,1 Operator Workarounds (71707)
a. Insoection Scoce
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The inspectors reviewed operator workarounds and implementation of a BGE
operations department process for correcting these deficiencies.
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b. 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 safety.
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
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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.
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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 risk.
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,
c. 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 concern.
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07.2) Plant Operations and Sdety Review Committee (POSRC)
a. Inspection Scope (71707L
The inspectors reviewed and observed activities undertaken by the POSRC.
b. 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 evaluations..
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 operation.
Based upon the review, plant maintenance and operations revised their plans for
control of fire detection equipment.
The inspectors ted that personnel giving presentations to the POSRC were
typically well prepared and able to satisfactorily respond to committee questions.
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
- performance and expectations.
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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 issues.
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 POSRC.
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c. 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-documented.
08 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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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
closed.
08.3 (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 closed.
08.4 (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
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-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 closed.
08.5 (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 closed.
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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 activities.
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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
- b. 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 work.
- c. Conclusions
The observed maintenance was conducted safely and in accordance with BGE
. approved procedures and controls. Workers were knowledgeable and performed
work effectively.
M1.2 Routine Surveillance Observations
a. 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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b. 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 criteria.
Cor clusions
The observed surveillances were conducted safety and effectively demonstrated
system operability.
M8' Miscellaneous Maintenance issues
M8.1 l . ant Housekeeping
a. 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 b. 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 area.
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 appearance.
c. 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
.
.
E2 Engineering Support of Facilities and Equipment
E2.1 Saltwater (SW) and Service Water (SRW) Systems Continued Operability
a. !nsoection Scooe (92903)
I.
The inspectors reviewed the BGE efforts to ensure continued service water system
operability and reliability. The inspectors also reviewed the BGE heat exchanger
performance monitoring.
b. 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) 50-317/96-01.
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 issue.
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 summer.
LER 96-01 also described the BGE plan to replace the existing SRW heat
exchangers with larger heat transfer capacity, plate and frame heat exchangers.
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 closed.
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 needed.
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 ,
'
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 issue.
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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:
1. 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 system.
2. BGE had not verified the fouling factors used in the heat exchanger design
calculations.
l
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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 unavailability.
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 closed.
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c. .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 implemented.
Revisions to the program may be required after the installation of new service water
heat exchangers.
BGE effectively implamented the operating procedures and corrective actions
necessary to maintain the operability and reliability of the SRW heat exchangers. '
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
a. 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,
b. 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 stored.
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
contamination.
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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c. Conclusions
Radiological controls were appropriately implemented for the areas toured. SWP
and survey maps reflected protective measures and area conditions, respectively.
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 identified.
R1.2 Control of Radioactive Materials and Cantamination
a. Insocction Scope (83750)
l
The inspector selectively reviewed control practices for radioactive material and
contamination during tours of the station,
b. 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 clothing.
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
l
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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
remonitored.
-
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
!
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 use.
The licensee initiated action to review these matters.
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General Contamination Cortrols.
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.
,
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 systems.
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,
c. Conclusions
BGE implemented a generally affective contamination control program. However,
criteria fcf use in evaluating laundry selected for re monitoring needed improvement.
Review of the radioactive source term present within the station, relative to the
effectiveness of instrumentation, remains to be completed.
R3 RP&C procedures and Documentation
R3.1 Air Sample Counting and Analysis .
a. 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 purposes.
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b. 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
purposes.
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 environment.
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 collected.
BGE concluded that filter loading would not adversely affect alpha transmission for
air sample analysis and conservative alpha transmission factors were used.
I c. Conclusion
BGE provided generally cunservative internal exposure control of its workers in its
applicadon of a weighted DAC for potential exposure to airborne transuranics.
,
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
e. 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 environment.
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b. 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 contamination. '
The inspector's review of the program identified the following:
-
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
fallout.
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
!
release point and was included in olfsite dose calculations.
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 noted.
BGE initiated a review of the above matter,
c. 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 issue.
R 3.3 Radiological Controls (External Dosimetry Program)
a. 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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b. 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 response.
BGE's performed extremity monitoring using the TLDs accredited under its NVLAP
program.
c. Conclusion
BGE implemented a generally effective external dosimetry program. No violations or
sdiety Concef ns Were identified.
R3.4 Radiological Controls (Internal Dosimetry Program)
a. inspection SconeJ83750)
The inspector reviewed the capabilities and testing of the licensee's wholn body
counting equipment.
b. 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 made.
-
BGE provided for a normal one minute count when whole body counting
personnel. BGE was using a limited radionuclide library for this counting.
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).
BGE initiated a review of this matter.
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c. Conclusion
BGE implemented a generally effective internal dosimetry piograns. No violations or
i
safety concerns were identified. However, areas for improvement were noted, l
1
R3.5 Radiation Safety Coverage During Spont Fuel Pool Work j
i
a. inspection Scot.e (71750)
The inspectors reviewed radiation safety controls during work in the spent fuel pool
area,
b. 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.
,
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 area.
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 area.
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 shield.
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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
- had been conducted on August 20,1997 end September 27,1997. Neither survey
indicated any significant change in radiation levels or contamination on the bridge. ,
BGE supervisors stated that the coverage for fuel handling had been interpreted
differently by various radiation safety technici.'ns,
,
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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 completed.
c. 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 requirements.
R5 Staff Training and Qualification in RP&C
a. 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 6.3.
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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 weakness.
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 efforts.
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 experience.
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 committee.
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 appropriate.
Based on the above, the inspector made the following observations.
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In early December 1997, BGE selected a new RPM who did not meet
applicable qualification criteria.
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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 Control.
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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 made.
-
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 weakness.
Individual qualifications, for those individuals noted not to have
received applicable training, were temporarily downgraded by BGE
pending training.
BGE initiated actions to review and evaluate all applicable recent
training provide in this area and provide additional training as
appropriate,
c. 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
procedures.
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 1997.
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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 noted.
'
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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 Audit.
-
BGE ina;Ld development of a Radiation Protection Improvement Plan and
initlated a corrective action program to address the programmatic concerns
q
identified.
-
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 noted.
-
l BGE issued additional corrective action documents (RCAR (97-04)) to
specifically address weaknesses in control and oversight of diving activities.
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 activities.
-
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 procedures.
-
BGE implemented corrective actions as outlined in its September 11,1997,
latter to the NRC.
-
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 areas.
-
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 procedures.
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23
{
The following observation was made.
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,
c. Conclusion
BGE has initiated comprehensive actions to improve the radiation protection
program at Calvert Cliffs. Strong management support and involvement were noted
in this effort.
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 inspected.
The following observation was made.
-
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 UFSAR.
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 appropriate.
R8.2 (Closed) Unresolved item (50 317&318/97-0213) Review air sampling and analysis
program.
This matter is discussed in Section R3.1 of this report.
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 report.
-
50 317&318/97 0214, Failure to implement corrective actions to identified
deficiencies in high radiation area access.
-
50 317&318/97 0215, Failure to provide instructions for a diver in a
radiologically control area.
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50-317&318/97-0216, Failure to control access to a very high radiation
area.
'
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50 317&318/97-0217, Failure to complete radiological surveys pr;or to i
personnel entry.
R8.4 (Update) Violation (50 317&318/97 06-04)
Failure to develop and implement a procedure for control of laundered contaminated
clothing.
The inspector's review of this riatter is discussed in Section R1.2 of this report.
R8.5 Housekeeping
The inspector noted that overall housekeeping was good.
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 presented.
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
, _
W. Paulhardt, Radiation Safety Supervisor Dosimetry
L M. Rigsby, Supervisor Radiation Technical Services
'
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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2
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 3.c
50 317&318/b7 07-02 VIO Radiation Safety Procedures required by Technical
Specification 6.4.1 were not adequately implemented
50 318/97 07 03
,
NCV Failure to meet containment purge valve isolation
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.3.c.
50-317&318/97 07 01 NCV Testing for the emergency diesel generators did not
meet Technical Specificatior 4.8.1.1.2.d.3.c.
50-318/97 002 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
50 317&318/97-02 13 UNR Review air sampling and analysis program.
Uodated
50 317&318/97 02 14 eel Failure to implement corrective actions to identified
deficiencies in high radiation area access.
50 317&318/97 02 15 eel Failure to provide instructions for a diver in a
radiologically control area.
50 317&318/97-02 16 eel Failure to control access to a very high radiation area.
50 317&318/97-02 17 eel Fallure to complete radiological surveys prior to
personnsi entry.
50 317&318/97 06-04 VIO Failure to develop and implement a procedure for
control of laundered contaminated clothing.
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 LER. Licensee Event Report
NCV Noncited Violation
PDR- Public Document Room
PEG Plant Engineering Guideline
POSRC Plant Operations & Safety Review Committee
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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, ATTACHMENT 2 \ ? e
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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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l E'; Independent Assessment Cruse
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Closing Reniarks Cruse
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Dive Corrective Actions
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Unclear Overall Control & Leadership
- Maintenance section ownership
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- Consolidation of procedures
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- Industry experience
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Maintenance Oversight l
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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
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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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! Site Radiation Protection Performance Improvement P
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Integrate Radiation Protection
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htto SitePrograms
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! o ALARA Planner Assigned to Maintenance
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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
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- 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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_ - - - - - - - - - - - - - - -
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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
~
RST Job Coverage Standards
i
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