ML20236P106
| ML20236P106 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/09/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236P089 | List: |
| References | |
| 50-317-98-05-EC, 50-317-98-5-EC, 50-318-98-05, 50-318-98-5, CAL-1-98-06, CAL-1-98-6, NUDOCS 9807160154 | |
| Download: ML20236P106 (39) | |
See also: IR 05000317/1998005
Text
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U.S. NUCLEAR' REGULATORY COMMISSION
REGION I
Docket Nos: 50-317;50-318
M'eeting Report: Reference: NRC Combined Inspection No. 50-317;318/98-05
Licensee: Baltimore Gas and Electric Company
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Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2
Location: NRC Region i Office
King of Prussia, Pennsylvania
Meeting Date: June 18,1998
. Prepared By: R. L. Nimitz, CHP, Senior Radiation Specialist
. Approved by: John R. White, Chief
Radiation Safety Branch
Division of Reactor Safety
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9907160154 980709
PDR ADOCK 05000317
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MEETING SUMMARY
1. Attendees
Attachment 1 to this meeting report identifies the attendees of the conference.
2. Purnose of Meetina
The meeting was a Pre-decisional Enforcement Conference to discuss the
radiological controls deficiencies experienced during replacement of nuclear
instrumentation detectors in the Unit 1 reactor annulus on April 9,1998. The
licensee's assessment efforts, relative to this matter, including root causes and
actions taken and planned, as specified in NRC Confirmatory Action Letter (CAL)
No.1-98-006, dated April 29,1998, were also discussed.
The conference served to satisfy the specifications in the CAL (i.e., items B.2. and
B.3) that the licensee inform the NRC of the findings of its assessment efforts
relative to the April 9,1998 event, including root causes and actions taken or
planned.
3. Licensee Presentations
BG&E discussed the various assessments performed of its radiation protection
program, the findings of the assessments, and the short and long term corrective
actions taken and planned to address identified weaknesses. BG&E also presented
the specific actions taken in response to its commitments documented in NRC
Confirmatory Action Letter (CAL) No. 1-98-006, dated April 29,1998.
Attachment 2 to this meeting sumrnary provides the licensee's slides used for
discussion purposes. Attachment 3 to this meeting summary provides the
licensee's June 17,1998, summary of actions taken and planned, as documented
in its April 27,1998, letter to the NRC, and in response to its commitments to the
NRC, relative to the April 9,1998 event, including those taken in response to the
CAL.
BG&E stated that the NRC Combined inspection Report 50-317:318/98-05, dated
June 2,1998, reflected the circumstances surrounding the April 9,1998, events.
BG&E, however, clarified two statements made in the report. 8G&E stated that the
final results of its Significant incident Finding Team concluded that those workers
who entered the reactor cavity on the early morning of April 9,1998, did properly
wear their sacrificial dosimetry; and that the General Supervisor Radiation Safety
attended the April 8,1998,11:00 p.m. pre-job meeting held prior to the entry of
the workers into the reactor cavity on the early morning of April 9,1998. BGE
acknowledged that these clarifications were minor in nature and did not affect the
substance of the findings and observations, and conclusions documented in NRC
Inspection Report 50-317:318/98-05, dated June 2,1998. ,
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Attachment 1
Meeting Attendees:
Baltimore Gas and Electric Comoanv:
Charles Cruse, Vice President-Nuclear Energy
Peter Katz, Plant General Manager
Kevin Cellers, Manager-Nuclear Engineering
Hearst Daman, Supervisor, Instrument Maintenance
Deborah Svendsgaard, Radiation Safety Technician
Thomas Pritchett, Superintendent, Technical Support
Steve Sanders, General Supervisor, Radiation Safety
Lawrence Smialek, Health Physics Consultant, Re ; stion Protection Manager
Lee Russell, Manager, Nuclear Performance Assessment
John Osborne, Acting Director, Nuclear Regulatory Matters
Nuclear Reaulatory Commission:
William Axelson, Deputy Regional Administrator, Region i
Singh Bajwa, Project Director, PD1-1, NRR
Larry Nicholson, Deputy Director, Division of Reactor Safety, Region i
Larry Doerflein, Chief, Reactor Projects Branch I, Region 1
A. W. Dromerick, Reactor Project Manager, NRR
J. Bradley Fewell, Regional Counsel, Region i
Tracy Walker, Senior Enforcement Specialist, Region i
Scott Stewart, Senior Resident inspector, Calvert Cliffs
John White, Chief, Radiation Safety Branch, Region 1
James Wigginton, Senior Reactor Health Physicist, NRR
John Lusher, Enforcement Specialist, OE
Thomas Moslak, Radiation Specialist, Region i
Ronald Nimitz, Senior Radiation Specialist, Region 1
James Noggle, Senior Radiation Specialist, Region 1
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Attachment 2
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Summary of Assessments and Findings
Short and Long Term Corrective Actions Taken and Planned
General Actions in Response to CAL No. 1-98-006
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Radiation Protection
Inspection Report 98-05
CAL 1-98-006
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Radiation Safety Section
Supervision Style
b
Insular Organization
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Discouraged Learning !
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Site Management
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Overreliance on results indicators
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No good indicators of behaviors
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Agenda
+ Opening Remarks Cruse
+ SIFT /Special Assessment Russell
+ Short Term Corrective Action Katz
NPAD Surveillance
+ Independent Assessment Cruse
Long Term Corrective Action
Site Wide Application i
+ Closing
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Assessments
+ Significant Incident Finding Team
l + Special Assessment Team (CAL B.3)
+ NPAD Surveillance (CAL A.3)
+ Independent Assessment (CAL B.1)
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Special Assessment Team
(CAL B.3)
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Special Assessment T m
(SAT) Members
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Manager, NPAD, Team Leader
i Outside Member, OSSRC
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Plant Health Physicist
Lead Assessor
General Supervisor, Mechanical Mr41ntenance
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IIPES Coordinator
Performance Management Analyst
Supervisor, Issue Assessment
Supervisor, Instrument Maintenance
Plant IIcalth Physicist
Sr Rad-Chem Instructor
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Insights
+ Inappropriate behavior
+RS management
+ RS indicators
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CAL 5.3
1 Review and assess performance
deficiencies in radiological protection to:
-Validate the root causes
-Assess the effectiveness of corrective
actions
1 2 Assess why previous corrective actions -
did not lead to effective radiological
protection performance nor prevent poor
Performance in the Reactor Vessel
Annulus work, April 9,1998
3 Include measures, taken and planned, to
improve corrective action effectiveness ,
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Process W
+ Review '97 and '98 RP significant
events and reports
-RCARs assessments, improvement
plans NOVs
+ Perform, ed a collective significance
analysis
-Identified symptoms
-Rolled up symptoms into common
weaknesses
-Identified underlying causes
+ Reviewed assessment & improvement
plans
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Common Weaknesses
+ Behaviors
+ Radiation Protection Fundamentals
+ Corrective Action and Self-Assessment
+ Risk Management
+ Oversight and Management ,
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Behaviors
Examples:
+ RST not using backout criteria i
+ Culture heavily dependent on skill of
RST l
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+ Rad worker behaviors to ensure own
safety were unclear
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Behaviors ~Y
Why: i
+ Prior RS management 1
-Very directive style
-Did not encourage upward
communication
+ RS procedures silent on numerous
expectations
+ Management assumed 200%
accountability understood
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Radiation Protection
Fundamentals
Examples:
+ Air samples not representative
+ Did not monitor realtime exposure
+ Stay time informally calculated and
monitored
+ SWP limits not based on latest work
l i plan
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Radiation Protection
Fundamentals
Why:
+ Insufficient RS management
observation, enforcement of
procedure compliance and
expectations
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+ Procedures inadequate in conveying ,
detailed expectations
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Corrective Action and elf
Assessment
Examples:
! + Most RP RCARs contained
-Shallow underlying causes
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-Narrow corrective actions
-Limited generic implications
+ Self assessment program ineffective
+ Some CAs not aggressively
implemented
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Corrective Action and Self I
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l Why:
+RS supervision discouraged CA and
+ RS management - low expectations
for RCARs
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+ Identification of behaviors / problems
discouraged
+ Self assessment coordinator
inexperienced / program immature
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Risk Management
Examples: l
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+RS supervision failed to monitor the
first Higher Risk jobs
+RS contingency / mitigation plans
weak
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Risk Management
Why:
+ RS risk program - 10 R/hr
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+ No RS priority attached to
1 HRA< 10R/hr
+" Higher risk" job was a maintenance
risk activity .
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Oversight and Manage ent
Examples: '
+ RST performance not identified as
major weakness (6/97,7/97,9/97) ;
! +INPO evaluation - pre job briefs and
communications (7/97) i
+ RS personnel performance not in RPIP
+ Management believed RS weaknesses
being addressed
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Oversight and. Management
Why:
+ Audit and evaluation performed during
non-stressed period
+RS management viewed problem
primarily outside RS
+ Effectiveness ofimplemented CAs not
assessed
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Common Weaknesses
+ Behaviors
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+ Radiation Protection Fundamentals
l + Corrective Action and Self-Assessment
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+ Risk Management
+ Oversight and Management
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Immediate Actions
+ Stopped work in U-1 RV annulus
+ Stopped use of remote alarming
dosimetry
, + Management oversight - higher
risk / higher rad work
+ Declared the event an NPI(SIFT) ,
+ Conducted site-wide safety break
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Immediate & Short Term
Actions (CAL A.1 & A.2)
All immediate and short term actions
are complete (4/27/98 letter to NRC).
+ Increased management
involvement
+ Increased supervisory oversight
+ Heightened worker awareness
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Increased Management
Involvement
+ VP and managers assessment of RCA
work
+ PGM reports to VP regularly on health
l of RP program
+ Health physics consultant to PGM/VP
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Increased Supervisory O]versight
+ Management review board
+ Supervisory Oversight for all RP
L Higher RiskWork(CAL A.1 & A.2)
-Planning meetings
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-Pre-job briefs
-In the field !
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Heightened Worker Aw eness
+ Improved Radiological briefings
-Incorporate lessons learned
-Awareness of dosimetry
requirements and location
-Awareness to alarming dosimetry
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-Stay time verification
-SWP compliance
+ Mandatory Training for RCA access
+ Ensuring understanding every
aspect of thejob
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NPAD Surveillance
(CAL A.3)
+ Checklist based on Management
expectations
+ 22 job observations
+ Observed integrated planning meeting,
prejob brief and job
-One occasion supervision not at pre job
brief
+ Supervision effective in ensuring
appropriate RC planned, communicated
and implemented (A.1 and A.2)
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Radiation Protection Results
+" Learning is taking place"
-
irs / Gold Cards
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Delaying work j
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Backing out of work 1
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Briefings
+ Outage results
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157 Person Rem
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No. unplanned exposures
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Assessments
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+ Significant Incident Finding Team l
+ Special Assessment Team (CAL B.3)
+ NPAD Surveillance (CAL A.3)
+ Independent Assessment (CAL B.1)
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a..essese.+es. Des **= -
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d ** ee.seess e.
Independent Assessment of
Radiation Safety Program &
Performance
(CAL B.1)
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Independent Assessment
(CAL B.1)
+ Strengths
-Commitment to ALARA
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-Worker and Supervisor show
improved SWP awareness
l -Management focus, effort and
short term action effective at
eliminating unplanned exposures
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Independent Assessment
+ Areas ofImprovement
-RS procedures
-Integrate RS risk management into
planning process
-RS staffing, skills and resources
-Reinforce RS fundamentals
-Quality of RS program indicators
-Single plan for Radiation Protection
Improvement
-Change management
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Goal: Excellent
performan, event-free
ce in Radiation SafetyY
Strategy:
1 Address common weakness
-Improve behaviors
-Improve RP fundamentals &
l practices
-Improve CA & SA
-Improve RP risk management process
-Improve oversight & management of
RP field activities
2 Continue compensatory measures
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RP Corrective Acti n
(Long Term) (CAL Item)
l + Continue RPIP
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-Improve site radiation protection
knowledge
-Improve radiation protection
assessments
-Integrate radiation protection into
work processes
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-Improve management oversight
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and communications ,
+ Update RPIP with lessons learned ;
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RP Corrective Actions
(Long Term)(CAL items)
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+ Standardize RP work practices
+ Simplify process, improve procedures
for work in RCA
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+ Conduct additional radiation safety
training
+ Leadership training in RS
+ Incorporate industry and site
experiences into job planning
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RP Corrective Actions
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(Additional)
l + Improve RP risk management
! process
+ Provide RS resources
+ Continue compensatory actions
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Assessments
+ Proceduralize long term
management oversight expectations
+ Additional RP program assessment
+ 0SSRC subcommittee on health of
RP program ,
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Site Wide Application
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Attachment 3
June 17,1998 Document
Specific Actions Taken and Planned as Documented
in April 27,1998, letter to NRC
Specific Actions in response to April 29,1998, CAL
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June 17,1998 l
The following is summary of actions taken as described in the April 27,1998 Baltimore Gas &
Electric letter and the related April 29,1998 Nuclear Regulatory Commission letter. All
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immediate and short term actions have been completed.
For additional information, contact Mark Draxton or John Osbome.
AREA No.1:
We committed that the five Calvert Cliffs Managers and the Vice President-NED would make
personal assessments of the radiological-controlled area (RCA) work on a regular basis to help
L assure that our expectations for the safe conduct of the work are communicated and met.
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In fulfillment of this commitment:
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During the week of April 27,1998 the Vice President-Nuclear Energy Division (VP-NED)
l requested all Managers-NED to join him in regular assessments of radiological contnslied area
work.
Documented observations were sent to the Radiation Protection Self-Assessment Coordinator,
and to the Vice President-NED. Expectations were again restated at the May 5th,1998 VP's
Staff Meeting.
The Radiation Protection Self-Assessment Coordinator reviews the observations, integrates the ,
observation results into a trending database, and provides feedback on the results.
AREA No. 2:
We committed that the Plant General Manager (PGM) would report regularly to the Vice
President-NED on the health of the RP Program,
in fulfillment of this commitment:
The VP-NED and PGM discussr,d the health of the Radiation Protection Program weekly
through the end of the Unit 1 octage. Radiation Protection performance indicators are also
reviewed during one-on-one meetince between the Executive Vice President-Generation and
VP-NED and between the VP-NED and the PGM.
AREA No. 3:
We committed that the VP-NED would make it clear to the Managers and key Superintendents
that they will hold people accountable for Special Work Permit (SWP) compliance,
in fulfillment of this commitment:
.
Since the April 9,1998 event, the VP-NED communicated to the Managers, Superintendents,
and Radiation Supervisors, during plant status meeting and other settings, that he will hold
people accountable for radiation protection.
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June 17,1998
AREA No. 3: (Continued)
This expectation was discussed verbally during the week of April 12,1998 and at the April 26th
meeting with Managers. It was re-emphasized in a memo to all Managers, Supervisors and
Work Leaders dated May 11,1998.
AREA No. 4:
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- We committed that we would communicate with senior management of all the major contractors .
l onsite about these events. With regard to contractors involved in this issue, the VP-NED would
) ' direct their senior management to assess and take corrective actions for these events. )
In fulfillment of this commitment:
l - On April 17,1998, the VP-NED personally contacted the management of the major site
contractors listed below to communicate the seriousness of the April 9,1998 radiation safety
events. He also clarified his expectations that radiation protection work must be conducted
event-free for the rest of the outage.
'
. Bartlett Mr. Bruce Bartlett )
. . Master Lee Mr. Richard Dobbs '
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. Framatome Mr. Charles England
. ABB. Mr. JeffIsakson
. . UNS Mr. Rich Hirsch
In the case of Bartlett, he also faxed a letter dated April 17,1998. On April 20th,1998 he meet -
with Mr. Nick DiMascio, Bartlett Vice President of Technical Services, to outline expected
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actions from Bartlett. On April 28th,1998 he had a second meeting with Mr. Nick DiMascio to
discuss the status of Bartlett actions. Action item status is documented in Mr. Nick DiMascio's
April 28th memo. Assessment feedback from Bartlett is being evaluated for inclusion into long
term radiation protection improvements.
AREA No. 5;
We committed that site personnel must significanity raise their awareness of responsibilities for
radiation safety. Under no circumstances should anyone perform a task without completely.
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understanding every aspect of the job and safety requirements.
In fulfillment of this commitment:
l
Following the April 9th,1998 events, a site-wide safety break occurred on April 16,1998 which !
discussed the radiation protection lessons leamed and generic implications. The expectation l'
was also communicated to site personnel via April 24th and 30th, 'Calvert Cliffs Hand-Outs.'
Additionally, the Superintendent, Nuclear Maintenance, reiterated the expectation to all ;
Maintenance personnel in his April 27th memo on " Radiation Safety". l
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June 17.1998
AREA No. 5: (Continued)
During the period of April 29 - May 6th,1998 the expectation was again emphasized to all
personnel.with RCA access during GOT Training 98-003.
In addition, the May 8th weekly outage safety topic " Radiation Protection Responsibilities"
provided additional details and reinforcement.
AREA No. 6:
l We committed that prior to the performance of planned outage radiation protection higher risk
work, the top level Management Review Board would recommend to the PGM that the work
would proceed safely. The recommendation would include clearly specifed line and radiation
safety ownership and other important safety criteria.
In fulfillment of this commitment:
Per the May 8,1998 Cellars / Sanders memo " Expectations for Higher Risk Radiological
Work / Risk Significant Work /High Radiation Work," all higher risk radiological work required an
integrated pre-job brief prior to the start of the work. Approval must be obtained from the
Ge,neral Supervisor-Radiation Safety (GS-RS), Maintenance Superintendent, Radiation
Protection Manager, and Plant General Manager following the pre-job brief in order to start the
work All changes in key personnel, unplanned radiological conditions, orjob scope required
another integrated brief and a management approval to recommence work. Approvals are
documented on the " Pre-Job Brief Approval Guide" (Attachment 2 of the May 8th
Cellars / Sanders Memo). Outage Control Center (OCC) Log contained copies of the approval
forms from each integrated pre-job brief. Originals are maintained in the respective
Maintenance Order (MO) package. ;
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AREA No. 7:
We committed that we would handle these items (opportunities to improve the pre-job planning l
and training for radiation protection higher risk jobs) in pre-job briefings immediately prior to
l conduct of thejob.
In fulfillment of this commitment: j
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This item is a 'statement of fact and is addressed in further detail in Areas No. 8 and 9.
AREA No. 8:
- We committed that we would establish multi-disciplinary teams to review radiation protection
l _ higher risk jobs and improve planning and training for them. The teams would involve
j stakeholder associated with each job. The goal for the reviews was to ensure planning and
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training for each radiation protection higher risk job that is conducted in advance of the pre-job'
planning.
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June 17,1998 '
AREA No. 8: (Continued)
In fulfillment of this commitment:
As described in the May 8th,1998 Cellars / Sanders memo " Expectations for Higher Risk
Radiological Work / Risk Significant Work /High Radiation Work," higher risk radiological werk i
required a planning " verification" meeting prior to the pre-job briefing for the work. The
objective of the planning verification meeting was to ensure that key players assig'ned '.o the job
thoroughly reviewed and understood the scope of work, and that procedures, mainteriance
work orders, SWPs, and other tools were adequate to safely implement the evolution.
Attachment 1 of this memo was used as a guide by the On-Shift Maintenance GS to ensure
that all appropriate discussions have occurred. These are located in the OCC Log for each
Integrated Planning Meeting. Originals are maintained in the respective MO package. The pre-
job brief checklists (Attachments 8 & g) were also used.
The planning verification meetings occurred typically three days before the high risk job was
scheduled to work. These meetings were identified in the Plan of the Day (POD) and in the
OCC on the radiological work whiteboard. The Radiation Safety planner / scheduler was
responsible for notifying the On-Shift Radiation Control Supervisor of upcoming planning
" verification" meetings.
Maintenance First Line Supervisors or Job Supervisors, On-Shift Maintenance GS, and
selected Radiation Safety Technicians who will be executing the work were required to attend.
- Additional players, such as Job Path managers, System Managers, Outage Coordinators,
Operations, etc., were asked to attend on a case-by-case basis as determined by the
Maintenance Job Supervisor.
The General Supervisor Radiation Safety (GSRS) assured assignment of involved radiological
personnel to assist with planning verification. He also insured other radiological resources, as
may be called for in the planning documents, were in fact available. The GSRS also reviewed
that planning and provides any concerns or comments to the planning verification meeting,
either directly or through his representative. The GSRS provided periodic oversight of the
planning verification meeting.
The Radiation Protection Manager (RPM) reviewed the planning and provided any concems or
comments to the planning verification meeting, either directly or through the Radiation Safety
First Line Supervisor, The RPM considered adherence to the Radiation Protection Program for
methods planned for work performance.
The assigned Radiation Safety (RS) Supervisor ensured the right resources were allocated to
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the planning verification meeting. The RS Supervisor assigned the radiation safety team for the
evolution and identified other Radiation Safety personnel for attendance at the planning
verification meeting. The RS Supervisor ensured required radiological information for the
planning verification meeting is brought to the meeting and identified follow-up radiological
issues were resolved prior to the pre-job brief.
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June 17,1998
AREA No. 8:(Continued)
The Lead Radiation Safety Technician (BGE Lead) attended and actively participated in the
planning verification meeting as directed by the RS Supervisor. The BGE Lead came to the
meeting with knowledge of the work to be performed, radiological conditions expected in the
work area, and pre-planned radiological controls.
I AREA No. 9:
We committed that in the interim, prior to achieving this goal, we would use integrated pre-job
briefings with Radiation Safety and line organization supervisory oversight to ensure readiness
to accomplish the radiation protection higher risk work.
In fulfillment of this commitment:
As described in the May 8th,1998 Cellars / Sanders memo, " Expectations for Higher Risk
Radiological Work / Risk Significant Work /High Radiation Work," all higher-risk radiological work
required an integrated pre-job brief prior to the start of the work. Approvals were obtained from
the GS-RS, Maintenance Superintendent, RPM, and PGM followina the ore-lob brief in order to
start the work. Any changes in key personnel, unplanned radiological conditions, orjob scope
required another integrated brief and all management approvals to recommece work. The
Pre-Job Briefing Checklist (Attachment 9) was used by the Maintenance Job Supervisor at the
brief. The Pre-Job Briefing Checklist (Attachment 8) was used by the Radiation Safety First
Line Supervisor to ensure that all required key elements were adequately addressed. The
Radiation Safety Supervisor ensured that all key participants are provided a copy of the SWP
and ALARA review. Completed Radiation Safety Pre-Job Briefing Checklists (Attachment 8)
are maintained in the SWP package. Completed Maintenance Pre-Job Briefing Checklists
(Attachment 9) are maintained in the MO package.
The objective of the integrated pre-job brief was to ensure all players in the evolution can
conduct the work in a safe and quality fashion. This objective was facilitated by following and
discussing items on the Pre-Job Briefing Checklists. The pre-job briefs occurred as close to the
start of the work as feasible. Typically, they were the day of the higher-risk evolution.
All key personnel involved in executing the evolution were present at the integrated pre-job
briefs. In addition, the On-Shift Maintenance GS and Radiation Safety First Line Supervisor
were required to be present. The On-Shift Maintenance GS and Radiation Safety Supervisor
used Attachment 2 to ensure that radiological risk was adequately managed, then they both
would obtain GS-RS, Maintenance Superintendent, RPM, PGM approval to commence work
using Attachment 2 as a guide for approval briefing.
The GSRS provided periodic oversight of pre-job briefs in order to assure expectations were
being met. He also assured that any feedback from the line or planning verification meeting
was evaluated and incorporated into briefings, as appropriate.
The RPM provided periodic oversight of pre-job briefs in order to assure expectations were
being met. He also assured that any feedback from the line or oversight was evaluated and
incorporated into briefings or the Radiation Protection Program, as appropriate.
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June 17,1998
AREA No. 9: (Continued)
The RS Supervisor ensured attendance by all Radiation Safety personnel actively involved in
the evolution. The RS Supervisor ensured that copies of SWP and ALARA Reviews were
provided to appropriate pre-job brief participant. Also, the RS Supervisor coordinated with the
Principal Radiation Safety Technician (PRST) or Radiation Safety Technical (RST) Lead, as to
who will be presenting the radiological portion of the pre-job brief. It was preferable that the
Lead PRST or RST present the radiological portion of the pre-job brief , so the RS Supervisor
could provide oversight.
The Lead Radiation Safety Technician (BGE Lead) may lead the radiological portion, based
upon experience and knowledge of the work. He actively participated in the discussion and
ensured an adequate understanding of radiological conditions and controls by pre-job brief
participants.
AREA No.10:
We committed that Radiation Safety Supervisors are informed of all RP higher risk work. All
radiation protection higher risk work would be overseen by BGE Radiation Safety and line
personnel.
In fulfillment of this commitment:
All RP Higher Risk work was discussed during the 0430/1300 meetings which were attended by
the RS Scheduler and OCC representatives. He would then relay this information to the RS
Supervisors via voice mail and at the 0500/1700 RS turnover meetings. All RP Higher Risk
work was discussed at the 0800 Managers Meeting and noted on the Plan of the Day (POD)
and on the Daily Report. Additionally, all high radiation SWPs are stamped with the words
" Contact RS Supervisor Prior to Pre-Job Briefs'.
This area is further described in more detail in the following two areas (as specified in the
4/29/98 NRC Confirmatory Action Letter (CAL)).
AREA No.10A:
We committed that relative to the current Unit 1 outage for radiological work that is determined
to be " higher risk," department supervision from the task organization and radiation protection
organization would provide periodic oversight of pre-job planning activities sufficient to assure
that appropriate radiation safety controls are established and integrated with the task, and
attend pre-job briefing efforts to assure that radiation safety control requirements are effectively
communicated to personnel responsible for the conduct and control of the work activity (CAL
A.1).
In fulfillment of this commitment:
As described in more detail in Area Nos. 8 and 9, per the May 8th,1998 Cellars / Sanders
memo, " Expectations for Higher Risk Radiological Work / Risk Significant Work /High Radiation
Work," Maintenance First Line Supervisors or Job Supervisors, On-Shift Maintenance GS, and
selected Radiation Safety Technicians, who would be executing the work, were required to
attend integrated Planning Meetings. Additional players, such as Job Path Managers, System
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June 17,1998
AREA No.10A: (Continugd)
Managers, Outage: Coordinators, Operations, etc., were asked to attend on a case-by-case
basis as determined the Maintenance Job Supervisor.
All key personnel involved in executing the evolution must be present at the Integrated Pre-Job
Brief. In addition, the On-Shift Maintenance GS and Radiation Safety First Line Supervisor
must be present. The On-Shift Maintenance GS and Radiation Safety Supervisor will use
Attachment 2 to ensure hat radiological risk can be adequately managed. Once satisfied that it
can, they both together will obtain GS-RS, Maintenance Superintendent, RPM, and PGM
approval to commence work sz;ng Attachment 2 as a guide for briefing approval.
AREA No.10B:
We committed that relative to the current Unit 1 outage for radiological work that is determined
to be " higher risk," lead or supervisory personnel from the task organization and the radiation
protection organization would provide direct oversight of field activities whenever actual work is
being conducted to assure that planned radiation safety controls are effectively established and
implemented (CAL A.2).
Ir, fulfillment of this commitment:
As described in the May 8th,1998 Cellars / Sanders memo, " Expectations for Higher Risk
Radiological Work / Risk Significant Work /High Radiation Work," BGE Supervisor / Sponsor and
Radiation Safety First Line Supervisor or Principal Radiation Safety Technician (PRST) were be
present at all times during the conduct of higher risk work.
The RPM and GSRS periodically oversaw higher risk work implementation in order to verify
effective implementation of pre-planning and Radiation Protection Program implementation. In
addition, observations of personnel performance for such practices as formal communications,
peer checking, and demonstrated use of STAR was performed.
The RS Supervisor or PRST provided continuous job site oversight for the implementation of
the work plan, as discussed in the pre-job brief and in accordance with work documents. The
oversight must have been at the pre-job brief and be a PRST or above. The oversight ensured
adequate controls were being implemented and coached personnel on peer checks, formal
communications, use of STAR and conservative decision making. No hands-on work was
allowed by the oversight individual.
The BGE Lead worked with the coverage technicians to implement the radiological controls.
The PRST ensured changing radiologicc! conditions were communicated to workers and that
conditions were within the bounds established by the back-out conditions. The PRST and/or
RST coverage persons performed peer checks to the extent possible to reduce pmential for
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error.
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June 17,1998
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AREA No.11:
We committed that we would take actions to strengthen oversight of contractor Radiation Safety
Technicians during the current refueling outage.
In fulfillment of this commitment:
As described in more detail in Area No. 4, we increased oversight of contractor Radiation
Safety Technicians in the field by adding two additional Bartlett HP supervisors, for a total of
two per shift. In addition, a Bartlett Vice President was periodically onsite and reviewed
expectations and performance in order to ensure that BGE expectations were achieved.
As described in more detail in Area No.10, BGE line and RS Supervisors provided supervisory
oversight for all RP Higher Risk work during the planning meetings, pre-job briefings, and in the
field.
Also, as discussed below in Area No.12, we have increased supervisory oversight of all
personnel, including contractors, by BGE Radiation Safety (RS) Supervisors as documented on
an observation checklist.
AREA No.12:
We committed to we would develop observation tools for RS Supervisors, similar to those used
in Nuclear Operations, to improve performance in field observations of work.
In fulfillment of this commitment:
Radiation Safety Policy Memorandum (RSPM)-022, " Radiation Safety Assessmem Program,"
was approved 6/11/98. This RSPM outlines the expectations for performing supervisory
observations. The purpose is to provide a " tool" to supervisors for conducting observations to
ensure personnel are meeting expectations.
AREA No.13:
We committed to implement a requirement for peer checks and supervisory review for a new
form to standardize stay time calculations which would ensure SWPs provide adequate
radiation exposure margin to accomplish work safely and maintain ALARA.
In fulfillment of this commitment:
Radiation Safety determines stay time calculation and documents peer checks and supervisory
reviews on a new Stay Time Calculation form. This form is placed with the SWP package.
Line items 22,23,24, and 25 of the Maintenance Pre-Job Briefing Checklist (Attachment 9,
May 8th Cellars / Sanders Memo, * Expectations for Higher Risk Radiological Work / Risk
Significant Work / High Radiation Work") ensured an independent verification of stay times and ,
that workers understood how they would know what their accumulated dose was and the I
criteria to exit the area.
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i AREA No.14:
We committed that at briefings for line workers, we would review the required dosimetry and its
proper location for radiation protection higher risk work.
In fulfillment of this commitment:
Line item 17 of the Maintenance Pre-Job Eriefing Checklist, (Attachment 9, May Oth
Cellars / Sanders Memo, " Expectations for Higher Risk Radiological Work / Risk Significant
Work /High Radiation Work") directed a verification that all required dosimetry had been
identified and placement of dosimetry on body had been discussed and understood.
AREA No.15:
We committed to have improved the ability to hear alarming dosimeters or will take
compensatory measures. A standard form was used to display the correct locations of required
special personal dosimetry. The maintenance pre-job brief form had been revised to prompt
worker verification of stay time, dosimetry requirements, and alarm audibility prior to
commencing work.
In fulfillment of this commitment:
In the ALARA Review package, a TLD/DRD/SAIC/ALNOR Placement Form was used to display
the current locations of required special personal dosimetry.
Maintenance Pre-Job Briefing Checklist (Attachment 9, May 8th Cellars / Sanders Memo,
" Expectations for Higher Risk Radiological Work / Risk Significant Work / High Radiation Work")
. Line items 22,23, 24, and 25 directed an independent verification of stay times a:id
ensured that workers understood how they would know what their accumulated dose was
and the criteria to exit the area.
.
Line item 19a directed a verification that the worker understood what to do if the EPD or
other instruments alarm and specifically directed personnel to leave the area and contact
Radiation Safety for all alarms.
.
Line item 19b directed a confirmation that the workers understood how they would verify
they could hear the alarm in the work area, and what action would be taken if alarms could ,
not be heard. At a minimum, a buddy system shall was used with increased monitoring of I
EPD reading.
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June 171998
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AREA No.18:
~
We committed that we would address sahe work in all RCAs at CCNPP and conduct training for
all personnel with RCA access' on these events and management expectations for worker
performance in any RCA.-
In fulfillrnent of this commitment:
l- Following the April 9th,1998 event, a site-wide safety break occurred on April 16,1998 which
discussed the radiation protection lessons leamed and generic implications.
'
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As directed in the April 28,1998 Vice President - NED memo to all Site Supervisors, Radiation
Safety Training was conducted for mil General Orientation Training (GOT) Part 2 employees
and contractors April 29 through May 6,1998 (l~ raining ID # GOT-98-003). In most cases, the
training was conducted by General Supervisors and Direct Reports to Managers, unless it was
more feasible for the First-Line Supervisor to do so.
The training applied to approximately 2,000' employees and contractors wh'o were GOT Part 2
only, currently on site. Off-site employees and contractors had RCA' access denied until
training was completei The training sessions were held in noise-free areas of the plant.
- On 4/30/98, the VP-NED's office provided additional clarification on expectations to all site
supenrisor's for training on dosimetry and dosimetry locations.
On 6/15/98, the key objectives from GOT 98-003 were incorporated into the GOT program, and
its respective computer-based training.
AREA No.17:
- We committed that we would retain Health Physics and Radiation Protection Manager
consultants to advise the PGM. The consultants would regularly brief the Vice President-NED
on the performance of the site Radiation Protection Program.
,
in fulfillment of this commitment:
Two Health Physics consultants worked together reviewing the site Radiation Protection
Program. Weekly, a consultant briefed the Vice-President-NED and the Plant General
Manager. The General Supervisor- Radiation Safety and the Radiation Protection Manager
were also in attendance.
AREA No.18:
We committed that an Institute of Nuclear Power Operations assist visit would be conducted in
,
radiation protection starting April 27,1998, to examine our site Radiation Protection Program.
In fulfillment of this commitment:
The INPO assist visit was conducted the week of April 27,1998.
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June 17,1998
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AREA No.19:
l We committed that the Significant incident Finding Team process would be completed and
causal factors identified. These will lead to long-term corrective actions.
1
in fulfillment c,f this commitment:
1
On June 16,1998, the Plant General Manager approved the results of a nine person Significant )
Incident Finding Team (SIFT). The SIFT performed an investigation of the April 9th events,
determined causal factors, and provided recommended corrective actions, CCER 98-02. These
{
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actions will be incorporated into the site Radiation Protection improvement Plan (RPIP). l
AREA No. 20:
We committed that we would assess the implementation of the Radiation Protection
improvement Plan and take appropriate corrective actions.
This area was further clarified in the April 29,1998 NRC Confirmatory Action Letter.
We will review and assess previous performance deficiencies involving radiological control
implementation to validate our determination of root cause and assess the effectiveness of
corrective actions; and by June 26,1998, provide our assessment of why previous corrective
actions were not effective in preventing the deficient radiological control performance relative to
the Reactor Vessel Annulus work activities on April 8 and 9,1998, including measures, taken or
planned, to improve corrective action effectiveness (CAL B.3)
In fulfillment of this commitment:
On June 17,1998, the Vice President-NED approved the results of a eleven person Special
Assessment Team (SAT). The SAT was appointed to provide an assessment of why previous
corrective actions from Radiological Protection events were not effective in preventing the
reactor vessel annulus entry event in April 1998, Supplement to CCER 98-02. These actions
will be incorporated into the site Radiation Protection improvement Plan (RPIP).
AREA No. 21:
We cornmitted that we would capture all iong-term corrective actions under our site Radiation
Protection Improvement Plan.
This commitment is long term.
AREA No. 22:
.We committed that we would strengthen the performance of Radiation Safety Supervisors and
Work Leaders by conducting leadership training.
This commitment is long term.
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June 17,1998
AREA No. 23:
We committed that we would conduct advanced radiation worker training for maintenance )
workers.
This commitment is long term.
AREA No. 24:
We committed that we would review processes used to conduct work in the RCA in order to
assure appropriate attention to important job steps and simplify steps where possible. This i
review would include line workers and supervision.
This commitment is long term.
AREA No. 25:
We committed that we would conduct an effectiveness review of radiation protection higher risk
work preparations. ;
This commitment is long term.
AREA No. 26:
We committed that we would improve the incorporation of our site and industry radiation
protection experience into job planning.
This commitment is long term.
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AREA No. 27: -
We committed that the Nuclear Performance Assessment Department would perform an
effectiveness review of corrective actions.
This area was further clarified in the April 29,1998 NRC Confirmatory Action Letter.
AREA No. 27A:
Relative to the Unit 1 Outage we will establish and implement a planned series of surveillance
or audits by either the quality assurance organization or other organizations, independent of the
task organization and radiation safety organization, to determine the effectiveness of the
actions described in items A.1 and A.2, above (CAL A.3)
In fulfillment of this commitment;
j
The Nuclear Performance Assessment Department (NPAD) assessors performed surveillance,
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1.e., assessments, on twenty-two maintenance and radiation safety activities that were
determined to be Radiation Protection Higher Risk (RPHR) evolutions. NPAD developed a
checklist based on management's expectations for RPHR evolutions. The checklist also
included items to allow assessors to verify current radiation protection work practices, and the
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June 17,1998
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' AREA No. 27A: (Continuedi '
site's response to the CAL. NPAD conducted observations of the pre-job planning meetings,
pre-job briefs, and field activities. Observations of the RPHR evolutions were conducted
between May 3,1998 and June 1,1998. NPAD completed fifteen assessment reports based
on the observations. The specific details are available in the individual assessment reports.
NPAD concluded that Calvert Cliffs Nuclear Power Plant effectively implemented the actions of
items A.1 and A.2 of the Confirmatory Action Letter (CAL) dated April 29,1998.
- Radiation safety and maintenance oversight was effective. Adherence to safe radiological
work practices was consistently demonstrated.
. The radiation safety and maintenance supervisors provided oversight of all field activities
observed. All personnel, observed in the field, participated in the briefs.
. Management oveisight stopped some briefs when information presented by radiation safety
was eitherincorrect or unclear.
AREA No. 278:
During the Unit 1 Outage, we will engage the services of an independent assessor to assess
the quality and performance of ongoing radiological control activities (CAL B.1).
In fulfillment of this commitment:
An independent assessment of the plant's Radiation Protection Program and performance was
performed by Mike White (Safety Management Services,' inc.) and Pat Volza (Management
Strategies, Inc.).' The objectives of the assessment we,re:
1. Assess the plant's current program and implementation to prevent unplanned uptakes of
radioactive material and extemal exposures.
2. Assess the effectiveness of immediate action implemented as a result of the April 9,
1998 unplanned exposure. ,
3. Assess the effectiveness of corrective actions from previous event sand assessments.
4. Assess the quality and effectiveness of other important elements of the plant's Radiation
Protection Program and performance.
The independent assessment was performed from May 3-22,1998. The assessment included
field observations, personnel interviews, review of events, and review of documents.
Recommended actions will be incorporated into the site Radiation Protection improvement Plan
. (RPIP).
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