IR 05000317/1988024

Insp Repts 50-317/88-24 & 50-318/88-24 on 881011-13.No Violations Noted.Major Areas Inspected:Emergency Preparedness Program,Including Review of Previously Identified Insp Findings & Review of Organization

ML20206F959
Person / Time
Site:	Calvert Cliffs
Issue date:	11/08/1988
From:	Craig Gordon, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206F947	List: IR 05000317/1988024 ML20206F942
References
50-317-88-24, 50-318-88-24, NUDOCS 8811210413
Download: ML20206F959 (6)

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U.S. NUCLEAR REGULATORY COMISSION

REGION I

Report No /88 24 -

50 315/88-24 Docket No ,

License No DPR-53 Priority --- Category C l DPR 69

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Licensee: Baltimore Gas and Electric Company

, P. O. Box 1475 L

Baltimore, Maryland 21203 ,

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Facility Name: Calvert Cliffs Nuclear Power Plant Units 1 & 2 .

Inspection At: Lusby, Naryland Inspection Conducted: October 11-13, 1988

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b Inspectors: L dbR uw ll TY C.~ Emergenc,< Preparedness d a 'e Section, g don FRS$8, DRSS S. Peleschak, EPS l Approved By: / .

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y , Chief, EP5,

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Inspection Summary: Ins [

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50 317788 pection 74 on aOctober 11-13, 50 3187B8 20 1988 (Report No t

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Areas Inspected: Routine, announced safety inspection of the emergency i preparedness program including review of previously identified inspection i lindings, changes to the emergency preparedness program, review of ,

organization and management control, inspection of independent program i audits, and inspection of emergency response organization trainin Results: No violations were identified. The Emergency Plan Emergency [

Response Plan implementing Procedures (ERPIP), and the emergency planning  !

program are being implemented in a manner to adequately protect public health  !

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8311210413 es:1 e PDR ADOCK 05000317 Q PDC .

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DETAILS 1.0 Persons Contacted

• A. Anuje, Supervisor, Quality Audits Unit

• V. Bradley, Security Coordinator

• J. Carroll, General Supervisor, Quality Assurance D. Dean, Security Training Specialist

R.' Denton, Manager Quality Assurance and Staff Services J.Dickerson,QualItyAssuranceEngineer

• T. Forgette, Supervisor, Emergency Planning Unit i W. Freesland, Supervisor, Safety and Fire Protection

D. Shaw

• A.Vogel,LicensingEngineerSupervisor, Technical Training

• Denotes attend;na.e at exit meeting 2.0 1.icensee Actions on Previously '.dentified Items OPEN (50-317/88 04-01 and 50-218/88-05 01) During the loss of annunciator event found that some which occurred Emergency Action on February)1, Levels (EAL did1988, the inspector not conform to the guidance of NUREG 0654 while others were inappropriate for the levels of intended response. The licensee agreed to evaluate accident related symptoms, events, and compatibility with existing Emergency Operating Procedure The licensee established a task force of department representatives from radiation safety, operations training, emergency preparedness, and fuel cycle management to review current EAL's and compare them with the criteria and initiattnq conditions of NUREG 0654. Task force recommendations and EAL revisions were issued to the Plart Operations and Safety Review Cemittee (POSRC) and operations personnel for review and coment. Following resolution of coments, ERPIP 3.0, "lmodlate .

Actions" was revised to include updated EAL charpes and presented to '

POSRC on September 28, 1988. Theinspectornotedsignificantchangesin >

initiating conditions relative to emergency classific.ations for fission !

product barrier degradation, radioactivity release, and containment degradation. The changes, which are currently implemented, do not appear to decrease the overall effectiveness of the Emergency Plan. Hcwever, classroom training and performance training (demonstratian by ke; {

response personnel in drills or exercises) has not been omplete CLOSED annunciator(50-317/88 event, a 04-02 & 50 deviation 318/88 from ERPIP05-02)3.0During was madethebyloss the of licensee in that a partial staff augmentation and facility activation in response to the emergency was authcrized by the Site Emergency Coordinator SEC A Notice of Violation was issued for failure to itolement establish (e Emergency Plan Procedure _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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In the licensee's response of April 21, 1988 to the NRC tht:y believed that the actions taken for partial organization and facility activation were satisfactorywith in accordance to meet the intent ofThe the procedur ERPIP need3.0,ll for activationbut fu were not strictly following declaration of an Alert classification was emphasized to all departments in training and correspondence and the loss of annunciator Etl. changed as part of the licensee's comprehensive EAL revie .0 Changes to Emergency Preparedness Program The inspector reviewed the licensee's records of changes to the Calvert Cliffs Emergency Response Plan Implementing Procedures made during 1987 and 1988. Aside from EAL revisions, no ma Plan. Implementingprocedureswereevaluakorchangeswerenotedinthe ed during the 1987 exercise and are adequate and up to dat Page 14 of ina Emergency Response Plan was revised to reflect that ERPIP's are to be used at the Alert of the ERP!P's indicate that in some(or higher) classificatio Review cases initiating conditions also relate to the Unusual Event classification. The Supervisor, EP Unit stated that the ERP would be clarified to cover all emergency classification l One facility change occurred during 1988 by the addition of the Nuclear Emergency Facility (NEfl located on the first floor conference room of the HEF building. The Punction of the NEF as an emergency *esponse facility is to provide systems engineering and design engineering

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support to the control room and TSC during emergencies beginning at the Alert classification. These functions have been transferred from the l i TSC because most engineering staff, supplies, drawings etc. are I

, permanently located in the REF and therefore niore readily accessible at any time. Comunication links and a separate equipment locker have been i designated for NEF use during emergencies. In order to assess its adequacy, NEF capa!:ilities and function should be evaluated during the

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next scheduled exercis On September 21,1988, the licensee transmitted a letter to NRC l from the i indicating South relocation Service of the Building Operations to the Interim S'upport Center (OSC)

Office Buildin The inspectors j observed the proposed facility and found it to be adequate in size and

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space. The licensee provided a schedule of dates when the design,

construction, and transfer of the facility will be completed. Official use of the new OSC is expected in 198 A major upgrade in the licensee's onsite emergency communications system was completed in September 1988. The system entitled "Emergency ResponseSpeedDialNetwork",providesindividualspeed-dialtelephones for directors, managers comunicators, and key responders in each emergencyresponsefacility. To ensure comunication efficiency, each phone has speed dialing (two-digit code) end 3-way conferencin . - _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _

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The system appears to have the capability to improve information flow

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within and between facilitie The inspector found that to satisfy the requirements of 10 CFR 50, Appendix E.IV.B. rqarding annual review of the EAL's with State and local authorities .he licenseo schedules annual meetin s with key officials from the Maryland Department of Environment, benter for Radiological Health and Calvert and St. Mary's counties. Such meetings EPU z

were conducted indicated that thein1988 1986 and 1987, meeting was out for 1988 delayed due the Supervisor,ing to changes be made in i the EAL scheme, and e'sected the meeting to be held sometime in November a 198 .0 Independent Reviews / Audits Independent quality assurance reviews of the EP Unit are performed by

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the Qualitv Audits Unit and have been adequately conducted to meet the j t equirements of 10 CFR 50.54(t ) . The inspector reviewed the results of i audits conducted during 1986 and 1987 and discussed the preliminary l

fi.1 dings of the 1988 audit with EP ard QA staff Specific checklists were used by the QA staff to perform the audits in 1986 and 198 In 1988, the checklists were supplemented by INP0 ro The

guidance inspectors and resultedthe reviewed in aupgraded more comprehensive audit criteriap/checklist gram audi and noted j that auditors must interpret NRC rules if those items of the checklist i which relate to key EP program areas are to be used. For other

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programmatic areas, audit criteria are directly associated with the

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and 10 CFR 50, Appendix E.

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planning findings orstandards of 10 CFRidentifled recommendations 50.47 fb) by auditors could be consideredAny

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either as items of non-compliance or violations of NRC requirement i The inspector found that the checklist design is in need of i clarification for those items which auditors have linked to NRC rules.

j Further, discussions with members from the QA staff and EP staff

, revealed that a difference of opinion exists in the manner in which review criteria are to be applied.

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Tne licensee has maintained in effect an Emergency Plan and EP program to satisfy NRC regulations. The inspector explained that it was necessary for both EP &nd QA staffs to concur in what criteria would be used to perform future audit The Manager QA & SS, who has authority overbothUnits,agreedthatimprovedcoordInationbetweenthetwo staffs was needed and indicated that review criteria at:eptable to each Unit would be identifie Results of audits identified only minor EP Unit deficiencies. A corrective action system is in place to resolve program deficiencies and the actions taken by the EP staff appeared timely and technically adequat _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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Findings and recommendations are discussed by the auditor with the QA Supervisor and senior auditor. This appears to be the only A management involvement since results are transmitted directl from the auditor to the Supervisor, EP Unit. The inspector noted tha although QA management reports maintains do not receive the statur from authorization of open items either thewithin its Unit,QA Unit Supervisor, or General Supervisor, QA prior tn issuanc .0 Organization and Management Control The inspector held discussions with cognizant licensee management and reviewed documents on the emergency response organization and emergency preparedness program management. The inspection also focused on interfaces and coordination between onsite offsite, and corporate organizations and adequacy of management effectivenes Reorganization of the Nuclear Energy Division (NED) resulted in a change in reporting chain of the EP Unit. Ur 4 r the new organization the EP Unit will report to the Vice President, NED through the Radiation Safety Although this change General Supervisor and QA & SS Manager.an additional lovel theof manap:rment in Manager, QA & SS stated that upper level management attention and support for the EP Unit would continu A licensee Facility Change Request (FCR) has been made to remove the organization charts from the technical specifications to the FSAR. This will designate the FSAR as the controlling document for future changes of the onsite organization and subject any change to FSAR revie .0 Knowledge and Performance of Duties The inspectors reviewed the licensee's program for emergency response training and noted that Attachment 1 of ERPIP 5.4 identifies a training matrix of specific initial training for Pferent categories of personnel within the Emergency Response Or Thest include Site Emergency Coordinators directors, and team mem' ical vers emergency response facility for dose techn(SEC),ganization support, assessment, radiation surveys, inplant repair, first aid and rescue, and chemistr Discussions were held with the Technical Training Unit jTTU Supervisor who provided training lesson plans, examination material, ex) amination results, and attendance records of site personnel. Composite training records are maintained via the TTU database files. The TTU conducts General Orientation Training for new )ersonnel and site visitor Onsite ERO training is shared among tie TTU, EP Unit, and Operations Training Unit as follows:

The EP Unit is responsible for training of key FR0 personnel ante prcviding instruction in emergency classification, protective action recommendations, technical support, and immediate actions training; the TTU is responsible for inplant team training including teams to carry

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out onsite/offsite surveys, chemistry, first aid and dosimetr Both Units provide classroom training in the radiologlcal assessment area.

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Training of offsite fire departments and local law enforcement personnel is provided b respectively.y the Safety At least and Fireindividuals three Protectionare Unitqualified and Security in eachUnit ERO potitio Following interviews w(3)ith the Supervisor, TTU the inspectors

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determined that the background and experience cf instructors appeared i ad(quate to provide most ERO instruction. Instructors, who are most

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conducting walkthroughs, knowledgeable and developing about implementing scenarios, are usedprocedures, during dr ills and exercises only as controllers or observers and do not participate as responders. Since j instructors are considered qualified to function in many different response roles, the inspectors discussed with the Supervisors EP Unit

and TT Unit, the possibility of designating training instructors as part

of the ERO and provide them the opportunity to participate in drills and

exercise ! Lesson plans are detailed and focus on important response elements or

< implementing procedures. Self-study guides are used to supplement lesson plans to provide refresher training for inplant teams. Practical factor checklist. which require individuals to perform specific tasks

, associated with their response function are also used for offsite

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monitoring post-accident sampling, and dose assessment teams during n pect on o 1c e training records indicated that they were complete and up to date. Exam questions relate directly to lesson plan

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material. The ins ectors reviewed results of ERO training performed in 1 1988 approximate 1 300-400 records

- examin(ees, i.e., a 1 scores exceeded) and passing the 80% noted a criteri % pass rate of all Although performance of response personnel has consistently been 4 demonstrated in drills and walkthrough exercises, the inspector i questioned whether or not administration of exams is meaningful given

the high pass rate. The TT Unit Supervisor sta'ed that training materials would be evaluated to make ex minat. ions m

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7.0 Exit Meeting

l The inspectors met with the ir see personnel denoted in Section 1 at

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the conclusion of the inspection to discuss tha findings as present i in

this repor The inspectors also discussed same areas for improver .it, j

The licensee acknowledged the findings and ar, reed to evaluate them and institute corrective actions as appropriate.

I At no time during the inspection did the inspectors provide any written information to the licensee, i

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