ML20203F436
| ML20203F436 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/05/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203F390 | List: |
| References | |
| 50-317-97-06, 50-317-97-6, 50-318-97-06, 50-318-97-6, NUDOCS 9712170379 | |
| Download: ML20203F436 (38) | |
See also: IR 05000317/1997006
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U.S. NUCLEAR REGULATORY COMMISSION
REGION 1
License Nos. DPR 53/DPR 69
Report Nos. 50 317/97-06:50-318/97 06
Licensee: Baltimore Gas and Electric Company
Post Office Box 1475
Baltimore, Maryland 21203
Facility: Calvert Cliffs Nuclear Power Plant
Units 1 and 2
Location: Lusby, Maryland
Dates: September 14,1997 through November 1,1997
Inspectors: J. Scott Stewart, Senior Resident inspector
Fred L. Bower Ill, Resident inspector
Henry K. Lathrop, Resident inspector
James Noggle, Senior Radiation Specialist, DRS
Paul H. Bissett, Senior Operations Engineer, DRS
Laurie A. Peluso, Radiation Physicist, DRS
Approved by: Lawrence T. Doerflein, Chief
Projects Branch 1
Division of Fieactor Projects
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PDR ADOCK 05000317
G PDR 2
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EXECUTIVE SUMMARY
Calvert Cliffs Nuclear Power Plant, Units 1 and 2
Inspection Report Nos. 50 317/97-06and 50 318/97-06
This integrated inspection report includes aspects of BGE operations, maintenance,
engineering, and plant support. The report covers a seven week period of resident
inspection and includes the results of announced inspections by radiation safety and
operator licensing personnel.
Plant Operations
BGE actions to minimize risk during a reactor coolant pump seal replacement were notable.
During the seal replacement, a number of control room deficiencies were corrected. The
plant was recovered and returned to full power without complication.
The inspectors observed the BGE response to an automatic trip of Unit 1. Operator actions
were very good and included completion of the appropriate emergency operating
procedures, periodic status briefings, and detailed evaluation of plant conditions. BGE did
a thorough review of the transient and after the cause of the trip was understood and
corrected, a plant startup was authorized by management. The plant was restarted and
returned to full power without complication.
The conduct of operations was professional and safety-conscious. The operations and
engineering departments implemented multiple and detailed safety risk assessments for
planned safety related equipment outages. The applicable system Technical Specification
(TS) limiting conditions for operation (LCO) were entered and exited correctly for the
equipment outage times.
The inspectors found that while BGE had not met their established goals for the number of
control room deficiencies; efforts to reduce the total number of deficiencies had been
- aggressive. No existing deficiency represented an immediate safety concern.
The inspectorr determined _that operator preparedness for use of self-contained
breathing apparatus was weak. A number of operators did not know the location of the
j equipment, some operators wors f acial hair that would inhibit SCBA use, and some
- operators had not trained with the equipment for five years. BGE responded to
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inspector concerns by requiring that operators be clean shaven and establishing a
practical training plan for SCBAs.
! The inspectors reviewed the licensed operator requalification program and found it was
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implemented acceptably. Operator performance during the annual operating test was
i good. The operations and training departments worked effectively to maintain operator
knowledge and skills at desired levels of performance. Licensed operator exams were
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administered appropriately; however, the inspectors noted some concerns in the areas of
l simulator and JPM debriefs, JPM critical task identification, and evaluator cuing.
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Executive Summary (cont'dl
Maintenu 3
In general, maintenance was conducted safely and in accordance with approved
procedures. The inspectors observed during maintenance inspections, that workers
were knowledgeable and performed work effectively.
A leak repair activity on the high pressure main turbine was initiated without normal
engineering assessment. The effort was stopped by the BGE nuclear assessment
department af ter identification that fire protection, injection pressure, and injection
volume had not been assessed. The NRC inspectors considered the efforts of the BGE
nuclear assessment department to be aggressive and prudent, initial mainwnance
department preparations for the higt. pressure turbine leak repair were poor.
En9!DMilD2
in 1980, BGE increased the toxic material hazard from the on sita storage of liquid
ammonia from 55 gallon drums to a 5600 gallon storage tank without completing a
written safety evaluation. Further, BGE had approved the replacement of the 5600
gallon tank with an 8500 gallon tank without a written safety evaluation providing the
basis that the change did not involve an unreviewed safety question. Safety evaluation
screening reports completed for the tank installations, had not considered UFSAR
Section 1.8, or UFSAR Figure 1-2.
The inspectors found that BGE had stored ammonium hy6 oxide solution within the
protected area boundary without ensuring that the plant was fully prepared for a
potential spill of the storage tank contents. The need to place control room ventilation
in the recirculation mode or have the licensed operators don respiratory protection had
not been fully considered and procedures for response to an ammonia spill had not been
developed.
The inspectors concluded that BGE was takin0 appropriate actions to address industry
identified concerns 'with the f atigue of welds on the 18,2A, and 2B emergency diesel
generator lube-oil and jacket water piping systems, o
On infrequent occasions, aircraf t have been observed flying at low altitudes over the
Calvert Cliffs site, BGE had assessed airplane flyovers and concluded that flights over
the plant did not represent a significant safety hazard.
Plant Supp_qrt
The programs for radiologicel environmental monitoring (REMP) and meteorological
monitoring (MMP) continued to be effective. Management oversight of the REMP and
MMP was effective. The quality assurance audits were of sufficient technical depth
to identify and assess program strengths and weaknesses. BGE audits evaluated the
technical adequacy of implomenting procedures, technical specification and of fsite
dose calculation manualimplementation, and practices,
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Executive Summsry (cont'd)
The inspectors found that BGE had not developed and implemented a procedure to
prevent personnel contaminations from occurring as a result of contaminated Anti-C
clothing. Although no significant skin contaminations had been observed, Anti C
articles that had been returned to Calvert Cliffs from the laundry vendor, were at
times contaminated above the limits specified in tne Calvert Cliffs procedure for
laundering of Anti C clothing. However no proceduro existed ' J.ich specified actions
to be taken when articles were found above the monitoring limits, including criteria
for sample expansion, assessment of the contamination in excess of the limits, and
actions to ensure that laundered clothing contaminated above acceptable limits was
not made available for general use.
Communication deficiencies were observed in a radiation safety technician turnover
and in prejob briefing for a reactor coolant pump seal replacement.
Radiation safety technician performance weaknesses were observed during high
radiation area coverage of a reactor )lant pump seal replacement that included:
poor placement of an air sampler, lace of knowledge of radiation levels of a canister ,
that was located in the work area, and inadequate control of a worker who was not
wearing the required water resistant protective clothing and was observed spraying
down a highly contaminated seal cartridge.
Good control and oversight to prevent foreign material from entering the reactor
coolant system during reactor coolant pump seal replacement was observed.
During the initial containment entry following a reactor trip, two radiation safety
technicians were observed by the NRC inspector making a high radiation entry
without following the Special Work Permit requirement to wear the TLD on the
outside of the Anti-C clothing, with the beta window exposed.
The inspectots conducted walkdowns of various fire protection equipment, including
fire hydrants, sprinkler piping, hose and nozzle storage boxes, and emergency fire
pumps. All of the equipment was in good materiai condition and no problems were
identified,
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TABLE OF CONTENTS
EXECUTIVE SUM M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Il
TA BLE O F CO NT ENT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
Report D e t a il s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1. O pe r a ti on s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . *
01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 :
01.1 General Comments (71707) ...................... 1
- 01.2 Unit 1 Re actor Trip . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
02 Operational Status of Facilities and Equipment .............. 3
02.1 Engineerod Safety Feature System Walkdowns . . . . . . . . . 3 7
02.2 Control Hoom Deficiencies . . . . . . , . . . , , . . . . . . . . . 3 !
02.3 Use of Self Contained Breathing Apparatus . , . . . . . . . . . 4
05 Operator Training and Qualification . . . . . . . . . . . . . . . . . . . . . . 5
05.1 General Sc ope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
05.2 Ex am Cont e nt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
05.3 Exam Administration and Evaluation . . . . . . . . . . . . . . . . . 6
05.4 Continuing Training ............................ 8
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05.5 Remedial Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
05.6 License Reactivation .................-........9
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08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . 9
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08.1 (Closed) Unresolved item 50 317&318/95 10-01 ....... 9
08.2 (Closed) Unresolved item 50 317&318/95 10 02....... 10
11. M a i n i e n a nc e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
< M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
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M1.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
M1.2 - Routine Surveillance Observations . . . . . . . . . . . . . . . . . 11
Ill . Engine e ring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . 12
El Conduct of Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
E1.1 Onsite Storage of Ammonia and other Toxic Chemicals . . 12
E2 Engineering Support of Facilities and Equipment ............ 15
E2.1 Emergency Diesel Generator Piping Operability . . . . . . . . 15
E 8 .- Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . 16
E8.1 Aircraf t Flight Hazards . . . . . . . . . . . . . . . . . . . . . . . . . 16
IV - Pl a nt Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 !
R1 Radiological Protection and Chemiury (RP&C) Controls . . , . . . . 17
RI .1 The Radiological Environmental Monitoring Program . . . . . 17
H1.2 Meteorological Monitoring Program . . . . . . . . . . . . . . . . 19 !
R1.3 Secondary Chemistry Controliniplementat;on Chang . . . 20
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Table of Contents (cont'd)
! R2 Status of RP&C Facilities and Equipment . . . . . . . . . . . . . . . . . . 21
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' R3 RP&C Procedures and Documentation . . . . . . . . . . . . . . . . . . . 22 -
R3.1 Laundering of Contaminated Clothing . . . . . . . . . . . . . . . 22
- R4 Staff Knowledge and Performance in RP&C . . . . . . . . . . . . . . . . 24-
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R6 RP&C Organization and Administration . . . . . . . . . . . . . . . . . . . 26
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R6.1 Organization Changes and Responsibilities . . . . . . . . . . . 26- i
i R7 Quality Assurance in RP&C Activities . . . . . . . . . . . . . . . . . . . . 27 .
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R7.1 Quality Assurance Audit Program ' . . . . . . . . . . . . . . . . . 27 - i
R7.2 Quality Assurance of Analytical Measurements . . . . . . . . . 27
- S8- Miscellaneous Security and Safeguards Activities . . . . . . . . . . . 28
F8 Miscellaneous Fire Protection issues . . . . . . . . . . . ... . . . . . . . . 28 3
} V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 9 7
. X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 9 i
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- ATTACHMENTS
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Attachment 1: Partial List of Persons Contacted
Inspection Procedures Used
items Opened,. Closed and Discussed
List of Acronyms Used !
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Summarv of Plant Status
The inspection period began with Unit 1 shutdown to support replacement of a
reactor coolant pump seal. The reactor returned to full power on September 22,
1997. Unit 1 tripped from full power on October 24 due to a loss of condenser
vacuum (section 01.2) and was returned to full power on October 26,1997.
Unit 2 remained at full power during the inspection period.
l. Onorations
01 Conduct of Operations -
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01.1 Gentf el Comments (71707)
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Overall plant operations were conducted safely with a proper focus on
continued nuclear safety. At the beginning of the inspection period, Unit 1
was shutdown in Mode 5 to replace the 118 reactor coolant pump seal. The '
replacement required that the reactor coolant system (RCS) be placed in the
hQher risk, reduced inventory condition. In preparation, the operations
department conducted briefings and established a reduced inventory plan that
specified tra ning requirements, actions to minimize time in the reduced
inventory condition, compensatory actions to ensure inventory control, and
contingency actions should there be a loss of RCS inventory. Operators and
other key personnel were trained on the plan and briefings for critical work in
the containment included discussions of containrnent evacuation procedures. ,
The focus of training was personnel and nuclear safety during the higher riek
condition. The inspectors reviraved the BGE plan and observed its
implementation, BGE actions to minimize the risk of the reduced inventory
condition were very good and the seal was replaced without problems. During
the seal replacement outage, a number of control room deficiencies were
worked and cleared. The plant was recovered and returned to full power on
September 22,1997, without complication.
The inspectors reviewed the June 1997 World Association of Nuclear
Operators (WANO) evaluation of Calvert Cliffs. The report was based on a
two week team review of Calvert Cliffs activities in operations, maintenance,
radiation protection, t.nd other areas. The report discussed a number of
strengths and areas for iraprovement. No significant operability issues were
identified and the inspectors were generally aware of issues ra!3ed in the
evaluation.
Using inspection Procedure 71707," Plant Operatior.3," the inspectors
conducted frequent reviews of ongoing plant operations. In general, the
conduct of operations was professional and safety conscious. The operations,
maintenance, and engineering departments implemented roultiple detailed on-
line safety risk assessments for planned safety related equipment cutages that
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included safety risk and trip risk assessments. Maintenance was sequenced to
minimize the risk factors. The applicable system Technical Specification (TS)
limiting conditione for operation (LCO) were entered and exited correctly for
the equipment outago times.
01.2 Unit 1 Reactor Trio
a. Insoectios. Scooe
The inspectors observed and assessed a reactor trip on Unit 1.
b. Observations _ and Findinos
On October 24, at approximately 9:17 a.m., Unit 1 automatically tripped from
full power. In the control room, operators had observed a main condenser low
vacuum alarm followed within ten seconds by the automatic trip. The plant
responded to the trip as designed and there were no complications. The
inspectors responded to the control room and observed the performance of
Emergency Operating Procedure, EOP-0, " Post Trip Immediate Actions," and
EOP 1, " Reactor Trip." Following the trip, the operators observed that a main
condenser vacuum breaker had fully opened, causing a loss of main condenser
vacuum. Because the main condenser was not available, the reactor was
stabilized in Hot Standby using auxiliary feedwater and steam generator
atmospheric dump valves. The control room supervisor appropriately assumed
an oversight position and followed control of the transient and execution the
emergency operating procedures. Periodic status briefings were held with the
operators with a notable briefing during the transition between EOP-0 and
EOP 1. Prior to exiting the emergency procedures, the vacuum breaker was
shut, vacuum was restored, and main feedwater was restored to supply water
to the steam generators. The inspector considered the operator actions in
response to the trip and to implement the emergency operating procedures to
be very good. BGE reported the trip to the NRC in accordance with 10 CFR
50.72(b)(2)(ii).
A Significant incident Findings Team was assembled to review the trip, to
determine the root cause, and to recommend appropriate corrective actions.
The root cause was determined to be a poorly completed wire termination for
the vacuum breaker handswitch in the control room. A loose strand of wire
extemal to the termination had contacted an adjacent powered contact
causing a seal-in contact to close in the vacuum breaker control circuit,
opening of the vacuum breaker. As corrective action, BGE initiated a
100 percent inspection of the type of electrical connection that had caused the
problem, initiated a procedure upgrade to ensure wire terminations were done
correctly, and implemented training on the cause and corrective actions for the
problem.
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On October 25, when the cause of the reactor trip was known and corrected,
a plant startup was initiated. Full power was reached on October 26, and
there were no complications to the startup,
c. Conclusions
The inspectors observed the BGE response to an automatic trip of Unit 1.
Operator actions were very good and included completion of the appropriate
emergency operating procedures, periodic status briefings, and detailed
evaluation of plant conditions. BGE did a thorough review of the transient and >
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af ter the csuse of the trip was understood and corrected, a plant startup was
authorized by management. The plant was restarted and returned to full
power without complication.
02 Operational Status of Facilities and Equipment
02.1 Enaineered Safety Feature Systern.Wr;kdowns (71707)
The inspectors performed walkdowns of accessible portions of the Unit 2
emergency diesel generators and the combined control room heating,
ventilating, and air conditioning (HVAC) system. Equipment configuration was
consistent with plant drawings. Equipment material condition and
housekeeping in the areas were good. Several minor discrepancies were
brought to BGE's attention and were corrected. The inspectors identified no
safety concerns as a result of these walkdowns.
02.2 Control Room DeficiencJgg
a. Scoon
Tha inspectors reviewed BGE Operations Administrative Policy 93-7," Control
Room Deficiency Reduction Program," and its implementation. ,
b. Observations and Findinos
The operations department had assigned a senior reactor operator the
collateral duty of coordinating the control room deficiencies program. One
program goal was to have the control room deficiencies planned and scheduled
to work within three weeks of identification. The control room deficiency
coordinator trended the deficiencies and issued monthly status reports which
were reviewed by operations management. BGE management specified that
issues affecting safety be repaired on an expedited schedule.
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The inspectors reviewed the trend for the previous 18 months and compared the
current trend to 1996 results. The inspectors observed that, as expected, the
number of control room deficiencies were reduced during outages and trended
upward between outages. In September 1996, BGE had approximately
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40 control room deficiencies and met their goal of less that 55 deficiencies, in
rarly 1997, BGE established a more aggressive goal of less than 35 total control i
room deficiencies. The inspectors noted that the September 1997 total of
55 control room deficiencies was higher than the September 1996 total. Most of
the deficiencies required unit shutdown for repair. However, the inspectors ,
noted that the September 1997 total reflected BGE's recent efforts to reduce the '
deficiencies from a recer,t peak of 72 and included the correction of 17 control
room doficiencies during the Unit 1 reactor coolant pump seal replacement
outage.
The inspectors reviewed the outstanding r ontrol room deficiencies and
determined that no single item in the backlog represented an immediate safety
concern. The inspectors noted that those items with higher safety significance
- were repaired in an expedited manner.
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c. Conclusions
The inspectors found that while BGE had not met their established goals for
number of control room deficiencies, efforts to reduce the total number of
deficiencies had been aggressive. No existing deficiency represented an
immediate safety concern. BGE had focused management attention to ensure
that control room deficiencies when considered in ' heir aggregate did not become
a safety concern.
02.3 Use of Self Contained Breathino Aooaratus ISCBAs)
a. Insoection Scooe
The operational readiness of plant operators to use self contained breathing
apparatus was assessed,
b. Findinos and Observations
Self contained breathing apparatus were provided near the control room to be
used in event of a radiological emergency. BGE told the inspectors that in some
scenarios, breathing apparatus would be necessary to protect operations
personnel 45 minutes following an accident that included a significant ,
radiological release. On questioning by the inspectors on the readiness vf the
control room for hazardous material spills, BGE reviewed the engineering
assessments that had been completed for ammonia storage and responded that
the SCBAs could be used during hazardous material spills or fires; however, BGE
told the inspectors that no amount of hazardous material that would require
SCBA use was stored in the Calvert Cliffs protected area.
The inspectors observed that most operators were clean shaven; however, a
number of operators wore beards or other facial hair that would inhibit
immediate respirator use. The inspectors were informed that razors were
available for personnel to allow shaving if needed for respirator use. On
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questioning, some operators did not know the location of the self contained
breathing apparatus. Also, instructions on how to effectively don and use the
breathing apparatus were not provided with the kits.
Based on inspector questioning, a senior reactor operator demonstrated donning
an SCBA. The operator, from memory, successfully used the apparatus in four
minutes; however, the operator did not check the leak tightness of the mask and
did not check t'ne low pressure alarm prior to activating the SCBA. These
checks were specified in BGE training manual for SCBA use. The senior reactor
operator stated that although annual written examinations on SCBA use had
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been completed, practical SCBA training had not been offered for five years.
Plant operators that were members of the fire brigade regularly used SCBAs in ,
training.
Following questioning by the inspectors, BGE specified operators to be clean $
shaven and to have practical training on SCBA use. BGE also initiated a review
to determine if the need for SCBAs could be eliminated.
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c. Conclusions
The inspectors determined that licensed operator preparedness for use of self-
contained breathing apparatus was weak. A number of operators did not know
the location of the equipment, some operators wore facial hair that would inhibit
SCBA use, and some operators had not traineel with the equipment for up to five
years. BGE responded to inspector concerns by establishing a practical training
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plan for SCBAs and initiated a review to eliminate the need for SCBAs for
licensed operators.
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05 Operator Training and Qualification
05.1 General Scoce (71001)
A scheduled inspection of the Calvert Cliffs' licensed operators' requalification
program was conducted from October 20 24,1997, using NRC inspection
procedure 71001. The scope of the inspection included the observation of the
annual operating exams administered to one operating and one staff crew of
, licensed operators, the review of previously completed annual exams, remedial
actions taken for exam failures, and reactivation of inact!ve licenses. The annual
examination consisted of a static simulator and classroom written examination,
simulator scenarios and job performance measures (JPMs), which were -
performed both in the siraulator and in the plant.
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05.2 Exam Contant
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a. insoection Scoos ,
The inspectors reviewed the annual written and operating examinations for the '[
licensed operators being examined during the inspection. Also reviewed were r
previously administered exams and weekly training quizzes. l
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b. Observations and Findinas
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The inspectors reviewed the written exams administered during the week and
found the questions to be of good quality with an appropriate mix of high and ;
low cognitive level questions. Both Parts A and B written exams were -;
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i adequately constructed, and the distribution of questions was appropriate :
between different examinations.
The inspectors reviewed and witnessed the performance of several simulator and i
in-plant JPMs. The JPMs were relevant to operator tasks, were consistently
administered by different evaluators, were technically sufficient to discriminate i
operator abilities, and were apprupriately evaluated to identify weaknesses in
l performance. However, there were some NRC identified concerns regarding JPM !
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construction that were brought to the attention of BGE management. These i
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- 1) not identifying all critical tasks, 2) designating some JPM - i
- steps as critical that should not have been, and 3) not including evaluator cues in
many instances for inplant JPMs.
l The inspectors reviewed several simulator scenarios that were given to one
operating and one staff crew.. The scenarit,s were challenging and met the ,
criteria set forth in the examiner standards. The scenarios were diverse and
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utilized variously abnormal and emergency operating procedures.
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c. Conclusions
4 The f acility had developed annual licensed operator requalification exams that !
effectively tested the knowledge and abilities of alllicensed operators.
05.3 Exam Administration and Evaluation
a. Inspection Scooe
The inspector observed one operating and one staff crew complete two sections i
of the. written examination, perform at least two simulator scenarios, and perform
five job performance measures (JPM). The inspector also reviewed the facility
evaluation of both crew and individual operator performance,
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b. Observations and Findinas
The crews ard individuals passed their operating and written examinations.
Crew and individual operator performance during the conduct of the simulator
scenarios was good Communication, for the most part, was very good. Peer
checks were conducted frequently in an effort to ensure that all control board
manipulations were carried out correctly. Crew briefings were also held
frequently. Individual and crew performance was appropriately evaluated by
operations and training evaluators.
During one scenario, the senior shif t supervisor displayed such a dominant role
throughout the scenario that the f acility evaluators were unable to effectively
evaluate the performance of the control room supervisor or the reactor operator.
The decision was made to delay final performance evaluations for these two
operators pending their participation in another scenario during the next week's
annual exam. The inspectors agreed with this decision.
During a previous NRC annual requalification inspection, as detailed in inspection
Report 317 & 318/9510,it was noted by the inspectors that a management
representative from operations was not present during the simulator exams and
that f acility evaluators did not provide detailed results of the simulator exam until
alllicensed operators had been examined and the results reviewed by
management. The NRC stated that this long delay could reduce the effectiveness
of the evaluations. The inspectors noted during this inspection that operations
management was present during the conduct of the simulator exams for the
operating crew. An operations representative was scheduled to observe the
performance of the staff crew, but was unable to be present due to a schedJIing
conflict. Operations management stated that it is now common policy for
operations management to be present during all simulator examinations.
In an effort to address the inspectors' concern regarding simulator debriefs, the
facility instituted a policy to perform debriefs immediately following the
completion of each scenario. These debriefs consisted of not only informing
each individual and crew of pass /f ail results, but also pointed out what they did
incorrectly and what the correct actions should have been, The inspectors stated
that the timing of this debrief was inappropriate because it transferred the setting
from an examination mode to a training mode. Providing training in the middle of
an exam could inadvertently provide the knowledge needed by certain individuals
necessary for successful completion of subsequent scenarios, or other segments
of the exam, and thus distort the evaluation of skills and abilities. The inspectors
stated that debriefs should be provided as soon as possible after an individual's
entire exam has been administered, but not anytime prior to completion of the
entire examination phase for each individual. Facility management stated that
they had misinterpreted the pievious inspector's concern and that they would
again address the area of debriefs and make the appropr! ate changes to correct
this area of concern.
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Overall performance of JPMs was acceptable. As noted above concerning
scenario debriefs, the same occurred during the performance of JPMs. JPM
debriefs, including incorrect actions were discussed with the operators following
the completion of each JPM. Again, the inspectors stated that this was
inappropriate because it provided training during an examination phase. The
inspectors also noted that each JPM task standard, an essential element to a
systematic approach to training (SAT) based training program, was provided to
each c serator prior to their performing a JPM. This information is appropriate for
JPM construction; however, it is inappropriate information to be given to the
operator. Knowledge of the task standard can be utilized by any individual to
indicate the success path necessary to satisf act 3rily complete a JPM, an
inappropriate cue. Facility management acknowledged the inspectors' concern
and stated that appropriate ections would be taken to address this concern
during future examinations.
,
During the administration of the static written exam, which is administered in the
'
simulator,it was noted that seven opcrators participated in the first session, and
eight operators participated in the second session. The inspectors also noted
that there was only one proctor present to monitor and address questions during
both test sessions. The inspectors questioned the ability of one proctor to
maintain an awareness of allindividuals in this type of test environment, in an
effort to maintain examination integrity, the inspectors stated that for this large
of a class, there should be at least two proctors. Again, the facility agreed to
make the necessary adjustments based upon further evaluation. The inspectors
did not identify any indication of examination compromise.
The evaluations by training and operations department evaluators were effective
for those portions of the exam observed by the inspector. The inspectors agreed
with the 4cility evaluations. Documentation of test results appeared adequate in
all instances,
c. Conclusions
The annuallicensed operator requalification exams were administered and
evaluated acceptably; however, program enhancements were warranted in the
areas of test result debriefs, JPM information provided to the operators, and
static exam administration.
05.4 Continuina Trainina
The inspectors reviewed several Calvert Cliffs licensee event reports (LERs) that
occurred in 1996 and 1997 in an effort to determine if any of the events were a
result of inadequate training. The LERs reviewed did not indicate any
deficiencies in the knowledge level of individuals or inadequate training provided
by the training department. The facility recently developed and has been using
performance indicator graphs for crew and individual performance during
examinations and evaluations. Each crew was evaluated against various
performance categories similar to competencies listed in the NRC examiner
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.
9
standards. Each crew shift rating was compared to the average of all crew shifts
and each individual crew member was compared to the overall crew average.
Should an average for a crew or individual be lower than the overall average to
which the results are compared, operations or training management can initiate
remedial training as they deem necessary to enhance the knowledge level of a
crew or individual to bring them in I;ne with the average. The Calvert Cliffs
training department had implemented a continuing licensed operator training
program that met administrative and regulatory requirements.
05.5 Remedial Trainino
The inspectors reviewed remedial actions taken for those licensed individuals
who had f ailed any portion of their weekly training evaluations or their annual
toqualification exam. In this instance, the inspectors reviewed the remediation
documentation for five individual f ailures of a weekly written quiz, one individual
f ailure of a weekly simulator scenario evaluation, and two individual f ailures
during the annual simulator exam scenarios. Documentation of remediatior'
included a review of areas of weakness with the individuals and a retake of
another exam. In allinstances, the individuals passed their retake examinations.
The inspector concluded that the Calvert Cliffs' training department had taken
appropriato action in regard to those individuals who had f ailed any portion of
their annuallicensed operator exam. For those failures reviewed by the
inspector, appropriate remedial action had been taken, and documentation was
acceptable.
05.6 License Reactivation
The inspector reviewed the f acility's program for restoration of active operator
license status following inactivation and found the program to be acceptably
documented and administered. The records of three licensed operators, whose
licenses had been recently reactivated, were reviewed. The inspector noted that
the records were complete and reactivation requircments had been met in
accordance with administrative and 10 CFR 55.53(f) requirements. The
inspectors determined that the f acility had appropriately implemented the
program and regulatory requirements for reactivation of licenses for operators at
Calvert Cliffs Unit 1 and 2.
08 Miscellaneous Operations issues
08.1 (Closed) Unresolved item 50-317&318/95-10-01: Training facility did not
document individual operator evaluations except when a failure occurred. The
inspectors reviewed current and past simulator evaluations and determined that
the f acility evaluators were performing and documenting individual evaluations in
additir,n to crew evaluations. Based upon this review, the item is eh.
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08.2 (Closed) Unresolved item 50 317&318/95-10-02: Not requiring attendance at all
requalification training and individuals missing training. The inspectors reviewed
records of participation (by attendance)in the licensed operator requalification
training program and discussed this area with facility management. In
accordance with f acility procedures and management expectations, alllicensed
operators were required to attend all continuing training sessions. The inspectors
reviswed the tracking process for five individuals who had missed occasional
training sessions the past year, it was determined that the facility adequately
tracked and followed up on the missed training sessions. Missed classes were
made up by attending either subsequent shift training classes or viewing video
sessions of previously conducted training. The inspectors determined that the
training department had adequately tracked missed training classes and that
individuals routinely made up training that they had missed. Through a review of
quarterly operations and training interface meetings, the inspectors noted that
continued emphasis was being placed on the importance of attending all
scheduled classes. Based upon this review, this item is closed,
ll< Maintenance
M1 Conduct of Maintenance
M 1.1 General Comments
a. inspection Scope (62707)
The inspectors reviewed maintenance activities and focused on the status of
work that involved systems and components important to safety. Component
f ailures or system problems that affected systems included in the BGE
maintenance rule program were assessed to determine if the maintenance was
effective. Also, the inspectors directly observed all of portions of the following
work activities:
MO2199700634 23 Saltwater Pump Motor, Breaker, and Controls
MO2199602803 Repair Expansion Joints for Unit 2 Diesel Rooms
M01199700292 Replace Seals and Boarings on 1 A EDG Prelube Pump
M01199704163 Boroscope 1 A EDG Cylinders
b. Observations and Findinns
The inspectors found that the selected maintenance activities were performed
safely and in accordance with approved procedures. Technicians were
experienced and knowledgeable of the assigned duties. Pre-job briefings were
effective in ensuring that the work was conducted in accordance with BGE work
protocols and plans. The inspectors noted that an appropriate level of
supervisory attention was given to the work. The BGE system engineering report
cards discusud problems, maintenance rule status, action plans for systems with
lower ratings, and problem trending.
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The inspectors were informed by BGE that a leak repair activity for the Unit 1
high pressure turbine casing had been stopped by the quality assurance
department on September 30. A Calvert Liffs Nuclear Perforrnance Assessment
Department inspector had identified during the pre job briefing that Calvert Cliffs
Maintenance Procedure LR 1,"On-line Leak Repair to Pressure Retaining
Components," had not been used in developing the leak repair work order. Also,
some considerations in procedure LR 1, such as a fire protection assessment, the
volume of sealant allowed, and the rpecified injection pressure for the sealant
had not been evaluated by BGE engineering. Instead, a vendor procedure had
been used to plan the work and the involvement of BGE engineering was
minimal. Following the work stoppage, plans for the leak repair were assessed
by Oalvert Cliffs engineering, appropriate procedurcs were imptomented, and the
job was completed on October 7,1997, without problems.
A reactor trip was caused by an improper termination on a ma.n condenser
vacuum breaker control switch. As corrective action, BGE inspected similar
electrical terminations and some additional problems were found and corrected.
A procedure change was made and training was conducted to prevent
recurrence. (See 01.2)
c. ConclusioD1
in general, maintenance was conducted safely and in accordance with approved
procedures. Workers were knowledgeable and pe-formed work effectively. A
leak repair activity on the high pressure main turbine was initiated without normal
engineering assessment. The effort was stopped by the BGE nuclear plant
assessment department af tor identification that fire protection, injection pressure,
and injection volume had not been assessed. The NRC inspectors considered the
efforts of the BGE nuclear performance assessment department to be aggressive
and prudent. Initial maintenance department preparations for the high pressure
turbine leak repair were poor.
M1.2 Routine Surveillance Observations
The inspectors observed and reviewed selected surveillance tests to determine
whether approved procedures were in use, details were adequate, test
instrumentation was properly calibrated and used, technical specifications were
satisfied, testing was performed by qualified personnel, and test results satisfied
acceptance criteria or were properly dispositioned. Tests that were inspected
included:
STP O 88-2 Test of 2B DG and No. 24 4Kv Bus LOCl Sequencer
0130 Nuciear instrument - Daily Survel: lance / Calibration
STP-0 73A-1 Saltwater Pump and Check Valve Quarterly Test
STP-F-490 Fire Detection Functional Test (Smoke)
STP-F-76 Staggered Test of Electric Fire Pump
STP-F-696 Diesol Pump Flow Test
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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 actions. The inspectors noted that an j
appropriate level of supervisory attention was given to the testing depending on !
, its censitivity and difficulty. For fire protection system testing, the fire and safety i
'
personnel were well organized and knowledgeable about the fire protection i
system. The procedures were clear and easily implemented. The fire protection
equipment was found in good material condition,
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lil. Ennineedna
E1 Conduct of Engineering
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- E1.1_ Onsite Storaae of Ammonia and other Toxic Chemicals {
1
a. insoection Scope
The inspectors reviewed the Calvert Cliffs on site storage of liquid ammonia.
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b. Findinas z7d Observations ,
'
The inspectors reviewed the Calvert Cliffs Updated Final Safety Analysis Report
(UFSAR), concerning the onsite storage of toxic chemicals. UFSAR Section
1.8, Generic issues, Subsection Ill.D.3.4, stated that the control room r
operators would be adeauately protected against the effects of accidental
release of toxic gases. The subsection referenced an evaluation of control 3
room habitability that was reported to the NRC in a BGE letter dated
December 30,1980.
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The December 30 letter to the NRC provided a control room habitability study
L as an attachment. The study stated in Section 2.8 that liquid ammonia was s
'
stored in 55 gallon drums,550 feet from the control r.,om intake. Further in
i Section 3.3 of the submittal, BGE stated that in the event of a drum f ailure, the
concentration of ammonia at the control room intake would be "30.0 ppm,
. much less that the ammonia toxicity limit of 50 ppm." BGE concluded in the -
i
evaluation that on site ammonia storage posed no hazard to control room
personnel.
The inspectors observed that ammonia was stored in a 5600 gallon container
- outside of the north end of the Unit 1 turbine building, in the vicinity of the tank
storage area. The inspectors noted that UFSAR Figure 12,"Calvert Cliffs Site
. Plan " showed that morpholine was stored at the location where the inspectors
observed ammonia storage. BGE informed the inspectors that the 5600 gallon
polyethylene tank had been installed in the tank f arm in 1986. At that time,-
BGE did not complete an unreviewed safety question evaluation in accordance
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with 10 CFR 50.59. The inspectors observed that a BGE design checklist
accompanying the modification which installed the tank had been checked *Not
Applicable" for a review of the Final Safety Analysis Report. .
In 1996, because the existing storage tank had degraded from ultra violet
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exposure, DGE initiated the replacement of the ammonia storage tank with an
upgraded 8500 gallon ammonia storage system. The new system included a
secondary spill containment, a localleak detection monitor, and a manifold for j
filling and venting the tank,
in preparation for the installation of the 8500 gallon system, BGE reviewed the
effects of onsite storage of ammonia for the 5600 gallon tank in June 1996. A .
BGE calculation completed at that time showed that the peak concentration of l
ammonia in the control room following a worst case spill of a 5000 gallon tank
containing 11 percent ammonia would be 137 pprn. A BGE engineer f amillar
with the calculation told the inspectors that the peak level of ammonia would
persist for about 30 minutes until the ammonia dissipated and that a number of
conservatisms remained in the evaluation. BGE reconclied the difference
between the 5000 0allon calculation and the actual 5600 gallon tank capacity
by stating that the existing tank was never filled above 3500 gallons.
The GGE control room habitability evaluation provided toxicity limits from the
Hazardous Chemicals Data Book (Weiss) of 100 ppm for 30 minutes exposures
and 500 ppm for 10 minute exposures. The Material Safety Data Sheet
provided by the ammonia supplier st sted that the immediate Danger to Life and
Health limit (IDLH) was 500 ppm 8"d specified respiratory protection using self-
contained breathing apparatus 'or longer term exposures at 250 ppm
concentration. Another reference, the Johnson Matthey Data Book, stated that
brief expuures to concentrations of 5000 ppm ammonia could be lethal. The
June 1996 BGE review concluded that ammonia at 137 ppm peak
concentration in the control room would not pose a toxic hazard following a
worst case spill.
1
The engineering service package for installation of the 8500 gallon tank had
been appro red for installation. However, the 10 CFR 50,59 screening report
that accompanied the service package did not evaluate applicability to UFSAR
Section 1.8 or Figure 12. Also, the engineering service package did not
provide for an ammonia tank leak detection alarm or ammonia concentration
readout instrumentation in the control room. The screening report answered
"No" to the question, "Will the proposed activity result in a change to the
safety analysis report description of the design, function, or method of
performing the function of any other structure, system, or component described
in the SAR?". The negative answer was based, in part, on the October 1996
control room habitability calculation, which concluded that a toxic hazard was
not created by the new tank. The screening report did not state that the
increase in the volume of the storage tank did not involve an unreviewed safety
question. The screening toport restated the conclusion of the June 1996
engineering calculation that the ammonium hydroxide solution would not
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constitute a toxicological hazard to the control room.
The inspector considered that the October 1996 review for installation of the
8500 gallon ammonia storage tank circumvented the 10 CFR 50.59 process.
'
Specifically, the December 30,1980 BGE letter to the NRC, described the
storage of 55 gallon drums of ammonia inside the Calvert Cliffs protected area.
The letter stated a control room peak concentration of 30.0 ppm ammonia and
stated a toxicity limit of 50 ppm. BGE justified not completing 10 CFR 50.59
reviews for the storage of increasing amounts of a hazardous material onsite
using the habitability calculations done in 19961n the screening reports. The
inspectors considered that the increasing amounts of ammonia introduced an
increasing hazard to contret room personnel, and that this hazard should have
been assessed in accordance with 10 CFR 50.59. Although the BGE
determination that the control room habitability remained viable, no specific
written safety evaluation had been completed to justify increasing amounts of
>
,
ammonia in the storage location and UFSAR Figure 12 was never updated.
The failure to document a safety evaluation which provided the basis for
determining that the increasing amounts of ammonia stored within the Calvert
Cliffs protected area was not an unreviewed safety question, was a violation of
NRC requirements (VIO 50 317&318/97 06 01).
The inspector also reviewed preparations for an ammonia spill onsite. The
inspector noted there was no emergency procedure that specified actions for
prots ction of control room or other personnel in event of a toxic chemical spill.
No pli.ns had been specified for personnel evacuation or use of the breathing
apparat is for ammonia spills. BGE informed the inspector that a procedure for
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combatir 1 a toxic chemical spill on site was under development. Failure to
have a procedure to combat a spill of toxic chemicals onsite, including
ammonia, was a violation of NRC requirements (VIO 50 317&318/97 06 02),
c. Conclusions
The inspectors found ' hat BGE had stored liquid ammonia since 1986 within
the protected area boundary without ensuring that the plant was fully prepared
for a potential spill of the storage tank contents. An evaluation of the need to
place control room ventilation in the recirculation mode and the need to have
the operators don respiratory protection had not been considered and
procedures for response to an ammonia spill had not been developed.
BGE had in 1986, increased the toxic material hazard from the on site storage
of ammonium hydroxide from 55 gallon drums to a 5600 gallon storage tank,
without completing a written safety evaluation. Further, BGE had approved
the replacement of the 5600 gallon tar'k with an 8500 gallon tank without a
written safety evaluation providing the basis that the change did not involve an
unreviewed safety question. Safety evaluation screening reports completed for
the tank installations, had not considered UFSAR Section 1.8, or UFSAR Figure
1 2. As a result, the UFSAR had not been updated.
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E2 Engineering Support of Facilities and Equipment
'
E2.1 Emeraency Diesel Generator Pioina Ooerability
a. Scope
The inspector reviewed BGE's actions and response to vendor identified
- concerns with welds on the emergency diesel generator lube oil and Jacket
water piping systems,
b. Findinas and Observations
in a preliminary 10 CFR Part 21 report, dated September 30,1997, the vendor ,
for the Calvert Cliffs 18,2A, and 2B emergency diesel generators (EDGs)
identified that a weld associated with the lube oil piping on a similar engine had
'
f ailed. The piping cracked at a partial penetration weld on piping that
experienced high vibration when the engine was running. The vendor noted
I that the root cause of this failure was undetermined and the analysis was
ongoing; however, the quality of the welds had been questioned.
, BGE had visually inspected the piping for evidence of leakage or cracking in
August 1997. Af ter the vendor notification was received, BGE personnel from
engineering and analntenance conducted additional visualinspections of each of
suspected welds on each of the engines. Vibration measurements were also
recorded.
Engineering developed an operability determination to support continued
operation of the EDGs. The operability evaluation noted that the available
industry and vendor information suggested that the weld f ailures were due to
high cycle fatigue. Based on the measured frequency of the piping and the
number of hours on the three opposed piston engines at Calvert Cliffs, BGE
engineering determined that a high cycle fatigue failure was unlikely. ,
'
Instructions have been issued for operations personnel to monitor the suspect
weld joints during engine operation. BGE planned to develop additional actions
in early 1998, based on recommendations from the EDG vendors' ongoing
investigation of this issue.
The inspectors noted that the vendor letter also identified that the jacket water
piping could be of concern and questioned why the operability determination
only addressed the lube oil piping. BGE stated that although there had been no
industry experience with failures in the jacket water cooling piping, the
operability determination would be revised to include this piping that was
addressed by the vendor preliminary report to the NRC.
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c. Conclusions
The inspectors concluded that BGE was taking appropriate actions to address
industry identified concerns with the f atigue of welds on the 18,2A, and 2B
emergency diesel generator lube oil and jacket water piping systems.
E8 Miscellaneous Engineering issues
E8.1 Aircraf t Fliaht Hazards
a. insoection Scoco
Recently, the inspectors noted two occasions of low flying aircraf t flights over
the Calvert Cliffs site. The inspectors also reviewed the applicable updated
final safety analysis report (UFSAR) and individual plant examination of external
events (IPEEE) sections related to the hazards from aircraft and discussed the
hazards with BGE personnel.
b. Findinas and Observations
The inspectors observed a large aircraft flying on a northwesterly course over
both containments at heights estimated to be less than 1000 feet on
September 17 and again on September 24. The inspectors notified BGE
management and this concern was entered into BGE's issue reporting system.
BGE personnelinformed the inspectors that the airspace over the plant was not
restricted. However, BGE contacted Patuxent River Naval Air Station (NAS).
The NAS personnel confirmed that pilots are trained to avoid flight directly over
the plant and indicated that they would reinforce these instructions in training
sessions.
UFSAR section 2.2.5.1 indicates that there are three airports within 11 miles of
the plant. The airport with the largest aircraf t and most flights is the Patuxent
River NAS. The UFSAR indicated that, during approach and departure using
instrument flight rules (IFR), the closest flight path would be seven miles from
the plant. During a review of the UFSAR in 1995, BGE identified that the flight
pattern data in the FSAR was outdated and current IFR flight paths would allow
flights over Calvert Cliffs ander certain circumstances. BGE initiated an issue
report into their corrective actions system that identified that a potential
unreviewed safety question had been identified as a result of the possible
increased probtbility of an accident. This issue report remained under BGE
review while the IPEEE was completed.
The IPEEE noted that flights over the plant were rare. The United States Navy
Airman's Information Manual directed pilots to avoid flyovers of the plant site
- and pilots from Patumt River were generally sent on three mile bypass loops
around the plant to avoid flyovers. However, three possible routes that fly over
the plant were iden4fied. An air traffic count provided by Patuxent River Naval
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17 ;
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Air Station identified that 214 flights used these routes within the past year. ]
This information was used to calculate a total frequency of an aircraf t crash ,
I
from Patuxent River NAS of 4.65x10E-9. BGE found that 74% of the total
probability of an air crash impacting vital structures comes from helicopter
operations which serve the Calvert Cliffs site. Subsequently, BGE established a
limit of six helicopter flights per year and has enforced this limit in their
contract with the vendor providing BGE helicopter services. Consequently, the
total aircraft crash and the related core damage frequene was determined to
be less than 1x10E 6. BGE personnelidentified that by .ie guidance in
NUREG 1407, Procedural and Submittal Guidance for 9 Individual Plant
Examination of external Events (IPEEE) for Severe * . ant Vulnerab iities, the
low probability of thit hazard did not warrant ca cu. ing a resulting core
damage frequency.
c. Conclusions
On infrequent occasions, aircraf t have been observed flying at low altitudes
over the Calvert Cliffs site. Based on the information provided by the
Calvert Cliffs IPEEE, the inspectors concluded that the recent flights over the
plant did not represent a significant safety hazard.
IV Plant SuDDort
R1 Radiological Protection and Chemistry (RP&C) Controls
R 1.1 The Radioloaical Environmental Monitorina Proaram
o. Insoection Scone (84750 2)
The following components of the radiological environmental monitoring program
(REMP) were inspected against technical specifications (TS) and the ODCM
(TS/ODCM) and NRC Regulatory Guide 4.1, " Programs for Monitoring
Radioactivity in the Environs of Nuclear Power Plants" to assess BGE
performance of the program:
- Sample collection from selected sampling locations;
- REMP procedures, the TS/ODCM, and UFSAR, including any changes
which pertained to REMP
- Revisions to the program implemented in 1997;
- Annual Reports of the REMP;
- Material condition of air sampling equipment t . automatic water
compositors relative to function, operability, and calibration;
- Thermoluminescent dosimeter (TLD) processing and handling;
- The land use census results; and
- Wind roses from the previous five years to asse:: any significant
changes since pre-operation to the present.
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b. Observations and Findinas
4
The inspector, accompanied by a BGE chemist responsible for implementation
and oversight of the REMP, visited selected sites where air samplerc, water
compositors, gardens, and TLDs were located. The inspector observed the
responsible personnel from BGE's contractor laboratory (Fort Smallwood)
exchange air particulate filters and charcoal canisters from the air samplers. The
inspector also discussed sampling techniques not observed, such as collection of
broad leaf vegetation, fish, soil and sediment. The observed air sampling '
equipment was well maintained and calibrated and the water compositor was
well maintained.
'
The intrector compared the sample locations in the ODCM with those in the
UFSAR and noted that the UFSAR, Section 2.9, Table 2 47 had not been
updatt J to reflect a footnote in the ODCM Table 3.121. The footnote *
, explained that cueln sample locations are not "in the general area of", "close
to", or "near the sita bi. 'ndary" for a direct radiation sample (DR1), an air
satapler (A1), and a food voduct location (Ib4, Ib5, Ib6), respectively. The
licensee was in the process if an UFSAR update and completed the 50.59
safety analysis during 'he I ,spection. The change appropriate to the REMP
program will be submitted to the NRC in November 1997. The inspector will
verify the change during a subsequent inspection. This is an inspection follow-
up item (IFl 50 317&318/97 08 03).
The inspector reviewed BGE Chemistry Procedure, CP 234, " Specification and
Surveillance for the Radiological Environmental Monitoring Program". The REMP
procedure contained appropriate steps for sampling, analysis, program
responsibilities and reporting requirements. The responsible personnel reviewed
the procedures for technical content, current practices, and requalification.
Procedure revisions were consistent with the current REMP changes.
The analytical results of samples from 1995 and 1996 (documented in the
annual reports) and from January through October 1997 were reviewed. The
inspector noted that the types and frequencies of analyses were performed as
required and the results showed no radiologicalincreases as a result of effluents
from the plant.
BGE replaced the TLD system for environmental monitoring with a more modern
system (Panasonic UD 814ASI)in September 1996. BGE performed the
. . comparison analysis of the previous and current dosimeter types for six months,
as required by ANSI N545 and Regulatory Guide 4.13. The inspector reviewed
the results and noted the results demonstrated no significant differences in the
two dosimeter types and met the ANSI criteria. The handling and processing of
the environmental TLDs were reviewed. The TLDs were analyzed by the
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chemistry unit of BGE's contractor laboratory, Fort Smallwood. The inspector
discussed with responsible personnel handling, processing, calibrating, and
maintaining the TLD reader and irradiator. Tiic inspector reviewed the
' associated procedures. The level of detail in the handling, processing, and
calibration of TLDs, provided assurance in the ambient radiation measurements
around the site.
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Tlio 1995 and 1996 annual reports of the REMP were reviewed to verify the
implementation of TS Section 6.6.2. The 1995 and 1996 annual reports
provided a comprehensive summary of the resu!!a of the REMP around the site i
and met the TS reporting requirements. No omissions, mistakes, or obvious
anomalous results and trends were noted.
The 1995,1996, and 1997 land use census were performed during August of
1995 and 1996, and June 1997 as required by the TS/ODCM. Performance of
the land use census was thorough and complete. No program changes (e.g.,
changes in sample locations) were required as a result of the census.
The inspector reviewed the wind direction assessments (wind roses) from the
past 10 years and compared them to the pre-operational wind roses to detect
changes,if any,in the prevailing wind directions. No significant changes were
evident. The environmental monitoring control station locations were reviewed
against the prevalent directions and the inspector noted that the control
locations remained valid in areas that are minimally impacted by the f acility,
c. Conclusion
Based on the above review, observation, and discussions, the inspector
determined the BGE performance in implementing the REMP continued to be
very good. The BGE sampling procedures contained appropriate information and
methods compared to industry standards and good practices. BGE
demonstrated a good working knowledge and understanding of the intent of the
REMP. Sampies were collected from the locations and frequencies specified by
the TS/ODCM.
R1.2 _Meteorotonical Monitorina Progu!m
a. Inspection Scope (84730 2)
The fohowing components of the meteorological monitoring program (MMP)
were inspected against TS, the UFSAR, and Regulatory Guide 1.23
commitmunts to assess the BGE performance of the program:
- Calibration procedures and methods;
- Calibration results of wind speed, wind direction and temperature sensors
and any related components;
- Operability and maintenance of instruments and equipment; and
- Modifications to the tower or associated instrumentation,
b. Observations and Findinns
The BGE Secondary System Engineering Department had responsibility to
calibrate and maintain the meteorological mmitoring instrumentation.
Calibrations of the wind speed, wind directio and temperature sensors were
conducted using the appropriate procedures. The inspector reviewed the
calibration results from 1995 through 1997. Calibration methods were
acceptable and the results were within the required equipment tolerances in the
-.- .- .. - - . - - - _ _ _ - - . _ . _ - - - -.. ----. . -- . -
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1
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20
procedures. The meteorologicalinstrumentation was calibrated at the ;
semlannual frequency, as required by the TS. The physical condition of the
equipment appeared to be good. BGE maintained a preventive maintenance ;
program to ensure equipment operability. Modifications to the tower and
associated instrumentation had been made since the previous inspection. The
modifications made included the addition of metal oxide varistors (varying
resistors) and surge protectors to reduce the effects of lightning strikes on the l
'
tower and instrumentation,
c. Conclusions
"
The inspector determined that overall, the BGE performance of maintaining and
.!
calibrating the meteorological m;,nitoring instrumentation was very good.
R1.3 Secondary Chemistry Control Imolementation Chanae j
a. lamection.Sagan
The inspectors reviewed changes to the BGE secondary chemistry control
program,
,
b. Findinas and Observations
'
'
On October 2, BGE implemented a change to the chemicals used in the
condensate and feedwater systems with the introduction of dimethylamine
(DMA) into these process streams (in Unit 1 only) to enhance corrosion control.
DMA is a low molecular weight organic amine which is highly volatile and has
been used successfully at several other nuclear plants for secondary chemistry
control. At a recent plant safety review committee meeting observed by the
inspectors, BGE engineers indicated that the primary benefits of DMA use would
be a further reduction in iron transport to the steam generators (S/G) and
lessened fouling of the secondary side of the S/G tubes. The engineers also
,
pointed out that DMA's reaction with copper alloys could result in an increase of
copper transport to the S/Gs, and copper is an aggressive corrosive towards S/G
'
tubes. The insoectors noted that committee members displayed a conservative
and questionir.g attitude, particularly regarding the safety aspects of DMA's
potentially deleterious effects.
The inspectors questioned whether personnel safety, including control room
operators, had been evaluated should a spill of DMA occur. BGE indicated that
,
a calculation (Calculation CA03489)had been performed which damonstrated
that the dilute concentration to be used (2%) was not a fire or toxicological
hazardi To further reduce the risk, only one 335 gallon container would be
permitted in the turbine building at any given time. The inspectors reviewed the
test procedure (ETP 97-067," Introduction of DMA mto Unit 1 Feedwater") and
'
the controlling chemistry procedure (CP 217, " Specifications and Surveillance:
Secondary Chemistry") and concluded that they contained, as appropriate,-
personnel safety precautions and warnings.
. _
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21
c. . Conclusions
The inspectors found that BGE had taken adequate precautions for a change in '
the chemical agents added to the Unit 1 secondary system.
R2 Status of RP&C Facilities and Equipment
a. Insoection Scopo
The inspectors reviewed the BGE programs for monitoring for personnel
contamination at the protected area boundary,
b. Observations and Findinas
BGE used portal monitors at both the entrance and exit to the protected area.
BGE told the inspector that the purpose of the monitoring was to ensure that
stray contamination was neither brought onto or taken from the site. The
inspectors were informed that contamination control for individuals working in
radiation areas in the plant was maintained either at the specific job site
boundary, at the exit to the auxiliary building, or both. BGE personnel stated
that the exit monitors at the protected area boundary served only as a backup
and not as a control point. The exit monitoring required a 10 second pause to
ensure effective dete: tion of radioactive material.
In 1997, BGE identified that some individuals were not pausing at the entrance
monitors in the Nuclear Office Facility (NOF). BGE conducted an assessment of
the effectiveness of the entrance and exit monitors and determined that a pause
should be required to monitor for contamination. To ensure that personnel acted
appropriately, BGE stationed radiation controls or security personnel at the
monitors until a high assurance of personnel compliance with the pause was
established. Additionally, both the entrance and exit monitors were posted that
a pause was required and the pause times were extended to ensure that a valid
count was completed. The inspectors observed that individuals entering the
plant properly paused until the radiation scan was complete. The inspectors
also observed that BGE posted a guard at the monitors during outage periods to
ensure that contractor personnel were aware of the pause requirements.
c. Conclusions
The inspectors concluded that the BGE monitoring and control of radioactive
material at both the entrence and exit to the plant protective areas was effective
for the intended purpose.
.
22
R3 RP&C Procedures and Docurnentation
R3.1 Launderina of Contaminated Clothina
a. Insoection Scope
The inspectors reviewed the BGE handling and re use of Anti Contamination
clothing (Anti Cs).
b. Findinos and Observations
in the 1996 Personnel Contamination Report, BGE identified that 21 personnel
contamination events had been attributed to contaminated re used Anti C
clothing. The report stated that this was an increase from 15 similar
occurrences in 1995. As a result, BGE specified that a self assessment of
contaminations from Anti C clothing would be conducted. The assessment,
which was completed in April 1997, identified a number of weaknesses in the
control of laundered anti-Cs, and recommended corrective actions. The
assessment concluded that the laundering process was adequate to prevent
significant skin contaminations from occurring (above the levelin which BGE
procedures required completion of a dose assessment). BGE changed the
vendor that provided laundry services et the end of March 1997. BGE informed
the inspector that no significant skin contaminations had occurred in 1995,
1996, or 1997.
The inspectors reviewed a BGE, August 1997 personnel contamination
summary, completed by radiation controls personnel. The report stated that 80
personnel contaminations had occurred in 1997 with 16 events attributed to
contaminated, re used anti Cs.
A personnel contamination was defined as greater than 100 counts per minute
above background on an individuals skin or clothing. A contamination was
normally detected during personnel monitoring at frisker stations on each level in
the auxiliary building or at the personnel contamination monitors at the exit to
the auxiliary building.
The inspector was informed that most used Anti C clothing was shipped to an
'
offsite vendor for cleaning. Upon return, five percent of the Anti-C clothis was
removed for contamination monitoring by BGE personnel. The remaining 95
percent were sont directly to the auxiliary building for use by plant personnel.
BGE stated that the monitoring was used to evaluate the effectiveness of the
vendor.
The inspector reviewed the results of laundry monitoring by BGE. An automated
detector system, with a limit of 25,000 decays per minute (dpm) or less to pass
the cloth!ng, was used to monitor individual pieces of clothing. Il levels above
25,000 dpm were observed, an alarm would sound and the pieces would be
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23 $
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identified as contaminated. Pieces with contamination less that 25,000 dpm !
were returned to the plant for general use. BGE informed the inspector that !
25,000 dpm was equivalent to 5000 counts per minutes per 100 square j
.
l centimeters, which was equivalent to five times the BGE free release criteria of j
100 counts per minute with a 20 square centimeter hand held probe. BGE ;
J considered less than 25,000 dpm of contamination on used clothing an i
acceptable risk for rt,diation workers wearing anti C clothing in the conduct of
radiation work.
I
A sample of monitoring results were reviewed by the inspector. On April 29,
'i
1997,84 hoods were tested and 2 failed, 563 cloth shoe covers were tested r
and 2 failed, and 78 coveralls were tested and 8 f ailed. On April 30,209 l
Jumbo rubber gloves were monitored and 59 gloves f ailed, and 189 extra large
totes were sampled and 113 failed. On May 17,20 large personnel clothing ;
(PCS) were sampled, and 11 f ailed,73 red gloves were tested and 23 fnited, j
and 254 Kevlar gloves were tested and 4 failed. Oli August 26,130 hoods
were tested and 8 f ailed,60 green boots were tested and 7 failed, and 122 ;
!
cloth booties were tested and 2 f ailed. ,
The inspector found th:st BGE did not have criteria for increasing the sample size
or dispostioning laundry when a high failure rate of monitored clothing was
i observed. BGE informally used the data to assess the vendor. As seen in the
some shipments, a large fraction of clothing sampled was above the monitoring
limits. Therefore, some shipments would result in a higher likelihood that a
personnel contamination would result from contaminated anti C clothing. ,
,
Additionally, the amount of contamination observed on articles that failed the
'
monitoring was not assessed to determine if a personnel hazard existed or if the
'
BGE acceptance criteria for laundering of Anti Cs (no significant skin
contaminations) could be exceeded.
,
Although no significant skin contaminations had been observed, Anti C articles
that had been returned to Calvert Cliffs from the laundry vendor were at times
!. contaminated above the limits specified in the Calvert Cliffs procedure for
laundering of Anti C clothing. No procedure existed which specified actions to
i be taken when articles were found auove the monitoring limits, including criteria
i
'
for sample expansion, assessment of the contamination in excess of the limits,
and actions to ensure that laundered clothing contaminated above acceptable
limits was not made available for general use. The f ailure to develop and
implement a procedure for control of laundered contaminated clothing was a ,
violation of NRC requirements (VIO 50 317&318/97 06 04). ,
'
During the review of contamination events from Anti C clothing, the inspector
.
learned of an event that occurred on April 7,1997. The event was documented
l in an issue report and involved an individual with detectable skin contamination,
L - but at a level below the 100 counts per minute definition of a personnel
' contamination incides.t. BGE generated the issue report after determining that
'
the comamination was greater than 50 cpm but less that 100 cpm and had not
been documented in the personnel monitor alarm log.' The inspector was
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.
24
successfully decontaminated. For this event, the inspector was informed that
because the auxilisry building monitors were 10 percent ef ficient for detection of
contamination, the individual may have indicated an uncorrected count of about
1640 decays per minute, that when divided by 10 for counter efficiency and
when the nominal outage background of 70 counts was subtracted, resulted in a
corrected count rate of about 94 cpm. Since the corrected count rate was less
than 100 creunts, it would not be a recordable personnel contamination event at
Calvert Chtfs. As a result, the inspector was concerned that the actual number
of problems resulting from poorly laundered anti-C clothing could be greater than
stated on the personnel contamination summary report. As noted above, an
issue report was written and BGE initiated changes to the personnel
contamination procedure to ensure that contamination events were properly
documented.
c. Conclusiong
BGE had not developed and implemented a procedure to prevent personnel
contaminations from occurring as a result of contaminated Anti C clothing.
Although no significant skin contaminations had been observed, Anti C articles
that had been returned to Calvert Cliffs from the laundry vendor, were at times
contaminated above the limits specified in the Calvert Cliffs procedure for
laundering of Anti C clothing. However no procedure existed which specified
actions to be taken when articles were found above the monitoring limits,
including criteria for sample expansion, assessment of the contamination in
excess of the limits, and actions to ensure that laundered clothing contaminated
above acceptable limits was not made available for general use.
The inspector found that some contamination events below the 100 count level
wete not documented in the personnel rnonitor log. Not documenting and
tracking these events was a poor practice and as a result, ths actual number of
problems resulting from poorly laundered anti C clothi 9 could be greater that
stated on the personnel contamination summary report.
R4 Staff Knowledge and Performance in RP&C
a. Srang (83729)
The inspectors performed a tour of Unit 1 containment and observed 118
raactor coolant pump seal replacement activities on September 16,1997. Also,
the inspector observed the initial containment entry following the reactor trip on
October 24,1997.
b. Qhiervations and Fip_ dings
Dui : tour of the Unit 1 containment, high radiation area barriers were
revL sd and evaluated. These barriers consirted of ladder locks and locked
stairway door barricades that were substantial. In addition, during entry to
containment and also prior to entering the high radiation area locked door
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ -
.
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25
leading to the reactor coolant pump area, radiation safety personnel verified
special work permit (SWP) authodzation, electronic dosimeter setpoints, and
worker knowledge of these setpoints prior to authorizing entry.
Af ter the old reactor coolant pump seal cartridge had been removed and placed
inside a storage canister, the radiation safety technicians (RSTs) conducted a
turnover. The on-coming RST received some information from the outgoing
RST. The on-coming RST was generally aware of the seal dose rates although
the beta radiation levels were not correctly passed along in the turnover. In
addition, the configuration of the seal stored inside a canister in the work area at
the time of the turnover had not been surveyed by the c r coming RST and no
turnover had been given on the canister dose rates. No instruction was provided
that this survey should be psrformed. Later, surveys revealed dose rates of 200
miem/hr on contact and 60 mrem /hr at 30 centimeters. This was a significant
radiation sourca on the work platform area (35 mrem /hr) which had not been
surveyed by tho responsible RST covering the workers. The oversight in
monitoring radiation levels at the work site was a significant weakness in high
radiation monitoring coverage of this job.
The inspectors observed good control and oversight to prevent foreign material
from entering the reactor coo: ant system during the pump seal replacement.
After the highly contaminated seal had been removed and placed inside the
storage canister, the work supervisor was observed handling the open canister
and spraying down the highly contaminated seal with water. This worker was
not wearing a set of water resistant protective clothing or a f ace shield as
required by Special Work Permit Number 802, task C. This doviation from the
SWP requirements was not stopped or corrected by the RST controlling the job.
Non-compliance with the SWP was a violation of the Calvert Cliffs Radiation
Safety Manual, Section 6.2.3.e (VIO 50-317&318/97-06-05).
During seal replacement activities, stationary low volume air samples were taken
at two different platform elevations. The air sample location on the pump seal ,
platform area was placed at the shroud circumference nearest to the platform
access ladder. The seal had been removed and rigged out from the opposite
- le of the shroud from the air sample location. In addition, a small 250 CFM
. EPA unit was located on the opposite side from the air sample location
drawing the seal area air flow away from the air sample. No personallapel air
samplers had been provided for the workers on this job. The air sample results
indicated 2.124 derived air cencentration (DAC) and 0.04 DAC during seal
removal and inspection activit:es, respectively. Due to the air sample location
and questioning by the .nspectors, BGE determined that the sample location did
not represent the highest airborne radinctivity hazard in the work area. The
inspectors considered that the sampling location representec an inadequate
survey and was a violation of 10 CFR 20.1501 pursuant to 10 CFR 20.1204
(VIO 50-317&318/97-03-06).
l
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. _ _ . . . . _ _ . _ _ __. . -__ __ _
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26
Following the reactor trip that occurred on October 24, the inspectors observed
two RSTs making an initial entry into the Unit 1 containment for air sampling.
, - The inspectors observed that the RSTs wore no respiratory protection anrf had -
- their thermoluminescent detectors (TLDs) and other dosimetry inside of their
protective clothing (Anti Cs). The RSTs informed the inspector that they were
entering containment using Special Work Permit (SWP) Number 11C. Toe
inspector observed that the S'NP stated that "In the absence of Respiratory
Protection or Facial Anti Cs, the TLD is to be worn on the outside of the Anti-
Cs." The discrepancy was pointed out to the Radiation Controls Shift
'
Supervisor and the Radiation Controls Superintendent. Following the event in a
typed statement, the RSTs stated + hat they had not entered the Unit 1
containment because lighting was not available when the inner containment
door was opened. For this reason, BGE informed the inspector that a skin dose
assessment was not necessary. However, the SWP was applicable when the
workers crossed the boundary that leads into the containment building. Non-
compliance with the SWP was a violation of the Calvert Cliffs Radiation Safety
Manual, Section 6.2.3.e (VIO 50 317&318/97-06-07).
c. Conclusions
'Although the licensee has tightened the controls for access into high radiation
i areas, control of work within high radiation areas was weak. Several problems
were observed in work performance during reactor coolant pump seal
replacement activities. Specifically, insufficient radiation safety technician
turnover of radiological information, an improperly positioned air sampler, and an
improperly dress worker was not stopped or controlled by the job coverage
radiation safety technician. Two violations were cited involving failure to take-
suitable measurements of airborne radioactivity and failure to comply with the
requirements of the applicable SWP.
During the initial containment entry following the reactor trip on October 24,
two radiation safety technicians were observed by the NRC inspector making a
high radiation entry without fo: lowing the Special Work Permit requirement to
wear the TLD on the outside of the Anti-C clothing, with the beta window
exposed. This was an additional violation of NRC requirements.
R6 RP&C Organization and Administration
R6.1 Oraanization Chanaes and Responsibilities
.The inspector reviewed organization changes and the responsibilities relative
to oversight of the REMP and MMP. No changes in the organ!:ation regarding
the oversight of the REMP or MMP were made since the previous inspection
in this area. The responsibilities relative to oversight of the REMP and MMP
have essentially remained the same. The BGE Chemical Technical Services
Department has primary responsibility for conducting the radiological
environmental monitoring program aad the Secondary Systems Engineering
_
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27
Department has primary responsibility for maintaining the meteorological
monitoring tower. The Fossil Engineering and Maintenance Department
Chemistry Unit of BGE's contractor laboratory (Fort Smallwood) were
responsible for the sampling and analysis of environmental samples.
R7 Quality Assurance in RP&C Activities
R 7.1 Quality Assurance Audit Prooram
a, 'Insoection Scoce (84750 2)
The following quality assurance audits of the BGE radiological environmental
monitoring program were reviewed:
- 1995 QA Audit Report (Report No. 95 3); and
- 1996 QA Audit Report (Report No. 96-16).
b .- Observations and Findings
The audits were conducted by the Nuclear Performance Assessment
Department (NPAD), formerly the Nuclear Quality Assurance Department
(NOAD). The audits covered the radiological environmental monitoring
program and were conducted by the BGE NPAD staff with assistance from
other technical specialists, including a specialist from another utility. Both
audits concluded that the Chemistry Department implemented a very good
environmental monitoring program. Both audits identified findings. These
findings were of minor safety significance and were closed. The next audit
in this area will be performed in 1998.
c. Conclusions
Based on the review of the BGE audits and discussions with an auditor, the
inspector concluded that BGE effectively identified and assessed the
radiological monitoring program strengths and weaknesses. The audits
evaluated the technical adequacy of implementing procedures and TS and
ODCM requirements. Performance of the audits was thorough, objective,
and of very good quality.
R7.2 Quality Assurance of Analvtical Measurements
a, insoection Scoce (84750-2)
The inspector reviewed the quality assurance (QA) and quality control (OC)
programs of the licensee's Fort Smallwood analytical laboratory.
_-_ _
. . . .. . . . .
... .. . . .
,
e
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28
b. Observations and Findinos
The inspector reviewed the programs for QA and OC of analytical
measurements for radiological environmental samples to determine whether
the licensee had adequate control with respect to sampling, analyzing, and
evaluating data for the implementation of the REMP. The Fossil Engineering
and Maintenance Department (FF.MD) Chemistry Unit implemented an
interlaboratory comparison program, required by technical speciiscations, .
through continued participation with the Environmental Protection Agency
(EPA) drinking water program and a program prnvided by Analytics,
incorporated. The inspector reviewed the analytical results. The inspector
noted that the results of the quality control and interlaboratory programs
were within the established acceptance criteria. The RGE quality control
program consisted of measurements of duplicato and split samples. The
inspector reviewed the analytical results and ..oted that the results were
generally within the acceptance criteria. When discrepancies were found,
reasons for the discrepancies were investigated and resolved,
c. Conclusior
Based on the above observations, the inspector determined that the
performance of the laboratory analyses was excellent and the interlaboratory
comparisor, programs were effective. BGE had a good quality control
program with respect to sampling, analyzing, and evaluating data for
implementation of the REMP.
S8 Miscellaneous Security and Safeguards Activities
The inspector reviewed a BGE investigation concerning fitness for duty of a
small number of workers at the site. The NRC inspection included review of
documents and discussions with BGE personnel. None of the workers
involved in the investigation conducted work on safety systems. The
inspectors found that BGE had conducted a thorough review and had
properly dispositioned all concerns raised during the investigation.
,
F8 Miscellaneous Fire Protection issues
During the period, the inspectors conducted walkdowns of varicus fire
protection equipment, including fire hydrants, sprinkler piping, hose and
nozzle storage boxes, and emergency fire pumps. All of the equipment was
in good material condition and no problems were identified. The fire and
- iafety personnel were well organized and knowledgeable about the fire
protection system (See M1.2), the fire protection procedures were clear and
easily implemented. The fire protection equipment was found in good
material condition.
l
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. .
_
_ _ _
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29
V. M_a.Lrm9emtqt Meetinas
X1 Exit Meeting Summary
During this intpection, periodic meetings were held with the plant general
manager and other station management to discuss inspection observations
and findings. Ori November 25,1997, are exit meeting was held to
summarize the conclusions of the inspection. BGE management in
'
attendance acknowledged the findings presented.
.
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_ _ _ _ _ _ _ _ - - _ _ _ _ _ _ .
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e
ATTACHMENT 1
PARTIAL LIST OF PERSONS CONTACTED
l E
P. Katz, Plant General Manager
K. Cellers, Superintendent, Nuclear Maintenance
K. Neitmann, Superintendent, Nuclear Operations
P. Chabot, Manager, Nuclear Engineering
T. Pritchett, Director, Nuclear Regulatory Matters
B. Watson, General Supervisor, Radiation Safety
C. Earls, General Supervisor, Chemistry
L. Gibbs, Director, Nuclear Security
T. Sydnor, General Supervisor, Plant Engineering
T. Forgette, Director - Emergency Preparednecs
M. Tonacci, Chemistry Supervisor
G. Barley, Senior Chemist
J. Carroll, PGM Alternate
B. Putman, NPAD Lead Assesscr
Fort Smahypod Laboratory
A. Kaupa, Senior Chemist
L. Bartol, Senior Chemist
R. Lassahn, Supervisor
NRQ
J. White, Chief, Radiation Safety Branch, DRS
INSPECTION PROCEDURES USED
IP 62707: Maintenance Observation
IP 71707: Plant Operations
IP 93702: Prompt Onsite Response to Events at Operating Power Reactors
IP 61726: Surveillance Observations
IP 37550: Engineering
IP 37551: Onsite Engineering
IP 71750: Plant Support Activities
IP 83750: Occupational Exposure
IP 92700: Followup of Written Reports of Events at Power Reactor Facilities
IP 92902: Followup - Engineering
IP 82701: Operational Status of the Emergency Preparedness Program
IP 83729: Occupational Exposures During Extended Outages
IP 84750: Radioactive Waste Treatment, and Environmental Monitoring
- _ _ _ - _ - - - _ _ - _ _ _ _ _ _ _ _ _
- - - - . - . .-
.'o
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- Attachment 1 2
ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened.
50 317&318/97-06-01 VIO The failure to document a safety evaluation for
increasing amounts of ammonia in the protected
area
50-317&318/97-06-02 VIO Failure to have a procedure to combat a spill of
toxic chemicals onsite, including ammonia
50-317&318/97-06-03 IFl UFSAR not consistent with the ODCM, REMP
program to be changed.
50 317&318/97-06 04 V!O Failure to develop and implement a procedure for
control of laundered contaminated clothing.
-50 317&318/97-06-05 V.O Failure to follow SWP requirements during RCP
work.
50 317&318/97 06-06 VIO Sampling location represented an inadequate
i survey during RCP work.
50-317&318/97-06-07 VIO Failure to follow SWP requirements during
containment entry.
. Closed
50 317&318/95 10-01 URI - Training did not document individual operator
evaluations during requalification exam.
50-317&318/95-10-02 URI Training did not require attendance at all
requalification training se::sions. *
LIST OF ACRONYMS USED
CFR Code of Federal Regulations
DAC Derived Air Concentration (radiation limit)
dpm decays per minute (radiation)-
EOP-O Emergency Operating Procedure for Post Trip immediate Actions
EOP-1 Emergency Operating Procedure for Reactor Trip
EDG Emergancy Diesel Generator
IPEEE Individual Plant Examination for External Events
LCO Limiting Condition for Operation (Technical Specification)
-
mrem /hr rnillirem per hour
NAS Naval Air Station (Patauxent)
RP&C 9adiation Protection and Chemistry
RST Radiation Safety Technician
SCBA Self-Contained Breathing Apparatus
a u aEa eA-
+
[*, l
1: ,
-
Attachment 1 3
SWP Special (radiation) Work Permit
UFSAR Updated Final Safety Analysis Report
- MOV Motor Operated Valve <
LPSI - Low Pressure Safety injection
IR BGE issue Report
GA Quality Assurance
TLD Thermoluminescent Dosimeter
MMP . BGE Meteorological Monitoring Program
NPAD BGE Nuclear Performance Assessment Department
ODCM Offsite Dose Calculation Manual
REMP Radiological Environmental Monitoring Program
TS . Technical Specifications
?
.