IR 05000317/1998008

Insp Repts 50-317/98-08 & 50-318/98-08 on 980719-0905.No Violations Noted.Major Areas Inspected:Plant Operations, Maint,Engineering,Plant Support & Emergency Preparedness

ML20154M264
Person / Time
Site:	Calvert Cliffs
Issue date:	10/09/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154M239	List: IR 05000317/1998008 ML20154M234
References
50-317-98-08, 50-317-98-8, 50-318-98-08, 50-318-98-8, NUDOCS 9810200213
Download: ML20154M264 (32)

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U.S. NUCLEAR REGULATORY COMMISSION

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Docket Nos: 50-317,50-318 License Nos: DPR-53/DPR-69 Report No /98-08,50-318/98-08 Licensee: Baltimore Gas and Electric Company Facility: Calvert Cliffs Nuclear Power Plant Units 1 and 2 Location: 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 Dates: July 19,1998 through September 5,1998 Inspectors: J. Scott Stewart, Senior Resident inspector Fred L. Bower lit, Resident inspector Tim L. Hoeg, Resident inspector Bill Maier, Emergency Preparedness Specialist, Region i Dave Silk, Emergency Preparedness Specialist, Region I

' Approved by: Lawrence T. Doerflein, Chief Reactor Projects Branch 1 Division of Reactor Projects i

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9810200213 981009 r!

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EXECUTIVE SUMMARY Calvert Cliffs Nuclear Power Plant, Units 1 and 2 l Inspection Report Nos. 50-317/98-08and 50-318/98-08 This integrated inspection report includes aspects of BGE operations, maintenance, .

eng leering and plant support. The report covers a seven week period of resident .

inspection and the results of a specialist inspection in emergency preparednes j l

Plant Operations I Plant operators manually tripped Unit 2 and conducted a plant cooldown in an effective manner. The identification of a small steam leak in a pressurizer penetration during a -

containment walkdown was an excellent example of detailed plant walkdowns and problem identification by plant operators. (01.2)

i A return of Unit 2 to power operation was completed without problems. Throughout the l various mode transitions, operators conducted extensive briefings and completed I evolutions in a controlled manner in accordance with plant operating procedure i Engineering support for the restoration of plant systems was very good including direct support of the feedwater, main turbine, and reactor coolant systems' engineers. Reactor physicists provided an accurate expected critical position calculation and were in the control room during the approach to criticality and power escalation. (01.1)

A conversion to improved Standard Technical Specifications was done during the I inspection period without apparent problems. (01.1)

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Maintenance  !

BGE conducted maintenance in an effective manner. Operational risk i.nsights were

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effectively used in maintenance planning and scheduling. (M1.1)

l The inspectors observed that the chemical treatment of the Unit 1 service water heat exchangers had limited success and unanticipated fouling of the heat exchanger surfaces

.was observed.- As a result, additional cleanings'of the heat exchangers were required and j adjustments were made to the chemical treatment frequency. (M1.1)

The surveillance testing performed during this inspection period was completed in a well controlled manner with minimal risk. Plant supervision provided active oversight during  :

testing. (M1.2) l l

Enaineerina BGE erosion corrosion engineering personnel erred in judging that some piping segments in  !

the Unit 2 steam plant were not susceptible to catastrophic failure due to flow accelerated ;

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corrosion. The result was a piping failure that led operators to manually trip Unit 2. The  ;

L BGE engineering review of the failure was extensive and included examinations of piping and review of program assumptions. Some piping segments in the Unit 2 steam plant were replaced with alloy piping material not susceptible to flow accelerated corrosion prior L to Unit 2 restart. (E2.1)

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Executive Summary (cont'd)

BGE engineering personnel were effective in their involvement and responsiveness to a smallleak on a pressurizer instrument connection. Engineering measures were taken to diagnose, document, and repair the leaking penetration. (E2.2)

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The inspectors observed system engineers conduct structure and system walkdowns of risk significant systems and concluded that thorough and competent engineering walkdowns were routinely performed. The observed engineers were knowledgeable of their system deficiencies and the impact of the deficiencies on operational safety. The i system engineers had a low threshold for identifying and recording new potential problem The EDG system engineers trended system parameters and provided good support during surveillance testing of the EDGs. (E2.3)

Plant Support BGE appropriately conducted radiological protection activities during the Unit 2 forced outage. The observed radiologically controlled area access check-ins were conducted in an acceptable manner and three-way communications were used. Pre-job briefings were thorough and comprehensive and the participants demonstrated good questioning attitudes. Radiation safety technicians provided good job coverage support including radiological surveys and worker monitoring. (R1.1)

Radiological assessments during emergency preparedness exercises were much improved

over previous observations. Procedure improvements made since the last NRC inspection j allowed for improved performance, but further procedure improvement was needed to l address concerns raised by the procedure users. (P4.1)

Emergency response training was being conducted as specified in the emergency response

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plan and emergency response group supervisors provided close oversight of training. BGE procedures did not specify how to evaluate or track personnel performance in order to l monitor the effectiveness of emergency response requalification training. (P5.1)

, The BGE initiative to more formally track and verify emergency personnel response from l offsite was considered an appropriate program enhancement. (P6.1)

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TABLE OF CONTENTS

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EXEC UTIVE S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

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l TABLE O F CO NTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv i Summary of Plant Status ............................................1 1. O pe r a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Operations (IP 717 07 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments .................................1 01.2 Manu al Reactor Trip . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2  !

08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 08.1 (Closed) Violation 50-317&318/96-10-01, Failure to Assure that Fuel Handling Procedures were Adequate . . . . . . . . . . . . . . . . . . 3

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08.2 (Closed) Licensee Event Report 50-318/98-004; Manual Plant Trip  !

Due to Moisture Separator Reheater Vent Line Rupture . . . . . . . . 4 I l

11. M a inte n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 l M1 Conduct of Maintenance (IP 6 2 707) . . . . . . . . . . . . . . . . . . . . . . . . . . . 4  !

M 1.1 General Comm ents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 i M1.2 Routine Surveillance Observations (IP 617 26) . . . . . . . . . . . . . . . 5 i M8 Miscellaneous Maintenance issues (IP 9 2 902) . . . . . . . . . . . . . . . . . . . . 6 M8.1 (Closed) LER 50-318/96-01, Automatic Plant Trip Due to Partial Loss of Of f site Power . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 M8.2 (Closed) LER 50-318/98-03, Relays Out of Calibration Due to Bumped Dial . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 M8.3 Closure of Violations involving 1997 Fuel Handling Activities . . . . 7 M8.4 (Closed) Violation 50 317&318/96-10 04, Incomplete Corrective Actions for Electrical Separation Barriers .................. 8 M8.5 (Closed) LER 50-317/97-09, Automatic Reactor Trip Due to Condenser Vacuum Breaker Opening . . . . . . . . . . . . . . . . . . . . . 8 M8.6 (Closed) LER 50-317&318/98-02, Fire Hose Stations and Room Sprinkler Systems Out-of-Service . . . . . . . . . . . . . . . . . . . . . . . . 9 M8.7 (Closed) Violation 50-317&318/97-05-02, Inadequate Corrective Actions for Problems identified with Compression Fittings ...... 9 111. En gi n e e ri n g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 E2 Engineering Support of Facilities and Equipment (IP 37551) . . . . . . . . . . 9 E2.1 Moisture Separator Vent Piping Failure . . . . . . . . . . . . . . . . . . . . 9 E2.2 (Closed) LER 50-318/98-005, Plant Cooldown Due to Reactor Coolant System Pressure 8oundary Leakage . . . . . . . . . . . . . . . 11 E2.3 Structure and System Walkdowns . . . . . . . . . . . . . . . . . . . . . . 12 E8 Miscellaneous Engineering issues (IP 9 2 903) . . . . . . . . . . . . . . . . . . . . 13 E8.1 (Closed) Violation 50-317&318/96-10-02, Failure to Support Dry Fuel Cas k Urh ading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 E8.2 (Closed) Licemee Event Report 50-317/98-03; Technical Specification Violation, Low Pressure Safety injection Inoperable . . . . . . . . . . 13

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Table of Contents (cont'd)

IV. Pl a nt S u p p o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . 14 R 1.1 Backshift Observation of Radiological Protection Controls and Activities .......................................14 R7 Quality Assurance in Radiological Protection & Chemistry (RP&C)

Activities (IP 92904) ....................................15 R7.1 (Closed) LER 50-318/97-003; Chemistry Sampling Not Performed as Required by Technical Specifications . . . . . . . . . . . . . . . . . . 15

'17.2 (Closed) Violation 97-03-01; Multiple Examples of Failure to Document and Report to Management Significant Conditions Adverse to Qu ality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 P2 Status of EP Facilities, Equipment and Resources ................ 17 P Severe Weather Communications Capabilities . . . . . . . . . . . . . . 17 P3 EP Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 P3.1 Emergency Response Plan Changes . . . . . . . . . . . . . . . . . . . . . 17 P4 Staff Knowledge and Performance in EP (IP 82206) . . . . . . . . . . . . . . . 17 P4.1 Radiological Assessment Capability . . . . . . . . . . . . . . . . . . . . . 17 P5 Staff Training and Qualification in EP (IP 8 2206) . . . . . . . . . . . . . . . . . 18 P Evaluation of Emergency Preparedness Training ............ 18 P6 EP Organization and Administration (IP 8 2 701 ) . . . . . . . . . . . . . . . . . . 20 P6.1 Emergency Response Organization Readiness . . . . . . . . . . . . . . 20 P8 Miscellaneous EP issues (lP 9 2 9 04 ) . . . . . . . . . . . . . . . . . . . . . . . . . . 2 0 P8.1 (Closed) Inspector Follow-Up Item 50-317&318/97-09-01 ..... 20 P8.2 (Closed) Inspector Follow-Up Item 50-317&318/97-08-04 ..... 21 (

P8.3 (C' sed) Violation 50-317&318/97-08-05; Failure to Test Communication Circuits. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 P8.4 (Closed) Violation 50-317&318/97-08-06; Training Deficiencies in Dose Assessment Capability . . . . . . . . . . . . . . . . . . . . . . . . . . 21 V. Man ag ement Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2 X1 Exit Me eting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2 X2 Review of UFSAR Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

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ATTACHMENTS Attachment 1 - Partial List of Persons Contacted inspection Procedures Used items Opened, Closed and Discussed List of Acronymns Used Emergency Response Plan and Implementing Procedures Reviewed v

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Report Details Summarv of Plant Status Unit 1 operated throughout the inspection period with no significant power reduction Unit 2 was manually tripped from 100 percent power on July 23,1998 due to a steam leak in the turbine building. The reactor was restarted on August 7 and returned to full power on August 9,1998. Power was reduced on August 14,19, and 29 to clean main condenser water boxes and on September 3 to complete repairs on a non-safety circulating water pump. Otherwise, the reactor operated without significant power reduction l. Operations 01 Conduct of Operations (IP 71707)

01.1 General Comments During a review of Unit 2 operations in cold shutdown on July 30, the inspector noted that an overpressure watch had been stationed in the vicinity of pressurizer controls while pressurizer level was maintained greater than 150 inches to facilitate maintenance. Plant procedures require an overpressure watch while filling the pressuriier to monitor reactor coolant system pressure and to take action if necessary, to prevent over pressurization. On questioning of shift personnel by the inspector, the actions to mitigate a pressure transient were not specified in the procedure and no special watch instruction had been prepared. The inspector raised a concern that protective actions to be taken, in event of a pressure transient, should be clearly specified and understood by watchstanders. Operations supervision agreed with the inspector concern and took action to clearly define and proceduralize over-pressure watch responsibilities. The inspector considered the BGE preparations for the over-pressure watch to be weak. Actions taken by BGE in response to the inspector concerns were timely and appropriat During a plant walkthrough on July 28, the inspectors noticed that the Unit 2 shutdown cooling purification flow was in excess of that allowed by the applicable operating procedure. The inspectors informed the control room and the auxiliary building operator was instructed to throttle the purification flow to the required flow rate. BGE documented the problem in an issue report (IR) and briefed shift personnel on purification flow rate requirements while in shutdown cooling. BGE considered the high flow condition was the result of increased shutdown cooling flow while reactor coolant system temperature was changed. Because the purification flow rate was being checked twice per shift, and had been satisfactory, the inspectors concluded that the high f!ow condition existed for only a short period of time. BGE engineering evalua'ed the flow condition and concluded that no adverse affects resulted.

l The inspectors observed significant portions of the recovery of Unit 2 from cold shutdown to power operation on August 6 and 7. Throughout the various mode transitions, operators conducted extensive briefings and completed evolutions in a f controlled manner and in accordance with plant operating procedures. Engineering l

t support for the restoration of plant systems was very good including direct support

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i 2 I by the feedwater, main turbine, and reactor coolant systems' engineers. Reactor i physicists provided an accurate expected critical position and were in the control I room during the approach to criticality and power escalation. Plant systems l functioned as designed and the return to full power operations was completed I without problem I l

During a plant tour on August 20, the inspectors identified that a locking device on ;

the component cooling water supply isolation valve to the 13 HPSI pump outboard l seal was in a condition where the valve could be operated without unlocking the i lock. The valve was full open. The subject valve is a normally locked open valve which is verified locked open semi-annually. The inspectors informed BGE operations personnel af the locking problem and BGE promptly corrected the locking device installation. BGE documented the locking device problem in an issue report and verified the other valves in the local area had their locking devices installed correctly. BGE concluded that there was no indication of tampering and the valve had remained in its normal open position. The inspectors considered the locking ,

device problem to be an isolated occurrence and the BGE response appropriate to i the circumstance '

On August 28, BGE converted to improved Standard Technical Specifications l (ISTS). The transition occurred by physical changeout of operations procedures, 1 technical specifications, and surveillance tests at noon. In preparation for the conversion, operators had used dual technical specification entries and tracking. A small number of technical specification interpretations remained in place after the conversion. However, action was in progress by BGE to eliminate all interpretations. At the close of the inspection period, the conversion to ISTS had been completed without apparent problem .2 Manual Reactor Trip Inspection Scope l

The inspectors responded to and reviewed the circumstances of a manual reactor trip of Unit Findinas and Observations

1 On July 23,1998 at approximately G:30 p.m, plant operators observed a steam leak in the vicinity of Unit 2 main tarbine moisture separator reheater piping. The ;

steam leak had little affect on plant operating parameters such as pressurizer level I and steam flow. Because the steam leak presented a personnel hazard and because l the source and consequences of the leakage were unknown, Unit 2 was manually l tripped from full power. Plant operators appropriately used emergency operating i

procedure, E-0, Reactor Trip, to stabilize the plant in hot shutdown. There were no complications to the trip and all equipment operated as designe l

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Following the reactor trip, operators isolated the steam leak first by shutting the main steam isolation valves, then using local valves in the affected lin Subsequently, the main steam isolation valves were re-opened and the condenser was used as a heat sink, while the unit remained in hot shutdown for investigation and repair of the steam lea The source of the leak was determined to be a ruptured two-inch steam line between the 21 moisture separator reheater and the 25 low pressure feedwater heater. The failure was subsequently determined to be the result of flow accelerated corrosion (FAC) in the carbon steel piping segment. (See E2.1)

As part of the post trip actions, and as a prerequisite to the return to power operations, a containment walkdown and inspection was conducted on July 24 by plant operations. This inspection included a search for deficient conditions such as evidence of leakage, adequate lighting, and a check that no foreign material was present in containment. During this inspection, a plant operator identified a small reactor coolant leak coming from a reference leg penetration into the pressurize The leak was identified by a hissing sound and was verified by direct observation by engmeering and maintenance personnel. Following verification of the pressurizer leak, Unit 2 was placed in cold shutdown as required by technical specification Conclusions Plant operators manually tripped Unit 2 and conducted a plant cooldown in an effective manner. The identification of the small steam leak in a pressurizer penetration during a containment walkdown was an excellent example of detailed plant walkdowns and problem identification by plant operator Miscellaneous Operations issues 08.1 (Closed) Violation 50-317&318/96-10-01, Failure to Assure that Fuel Handling Procedures were Adequate The violation involved three problems identified during fuel movements in the spent fuel pool, including a lack of assurance that the fuel handling ventilation system was properly aligned and two procedure adherence problems. BGE respor.ded to the violation in a letter dated April 4,1997. To assure that during a fuel handling accident the ventilation system would be capable of filtering fuel handling arec exhaust, BGE revised their fuel handling procedures and instituted a plant modification that provided indication of negative pressure in the spent fuel are The inspectors verified that the procedure compliance issues were corrected by l appropriate procedure changes and training of responsible personnel. During the I

1998 refueling outage, procedure compliance was observed during routine inspections of fuel handling and found to have been appropriate. BGE actions in response to the violation w e appropriate. The violation is closed.

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08.2 (Closed) Licensee Event Report 50-318/98-004; Manual Plant Trip Due to Moisture j

- Separator Reheater Vent Line Rupture l

The Licensee Event Report (LER) described the manual reactor trip of Unit 2 as discussed in Section 01.2 and E2.1 of this report. The inspectors observed or l

reviewed the short term corrective actions described in the LER prior to restart of l the unit, including repair of affected piping, augmented piping inspections, and l additional repairs. Also, there was a detailed BGE management review nf the l corrective actions prior to unit restart to verify that the actions taken were !

reasonable. The BGE actions in responding to the reactor trip were appropriate, !

including reporting in accordance with 10 CFR 50.72. The LER is close l ll. Maintenance M1 Conduct of Maintenance (IP 62707)

M1.1 General Comments Inspection Scope (62707)

The inspectors reviewed maintenance activities and focused on the status of work that involved systems and components important to safety. Component failures or

system problems that affected systems included in the BGE maintenance rule program were assessed to determine if the maintenaace was effective and the maintenance rule program was being appropriately administered. Also, the I inspectors directly observed all or portions of the following work activities

MO2199802274 Cut Out Tubing for Replacement Pressurizer Level 2-LT-110X j Instrument Nozzle IR3-029-999 Replace Power Supply (Steam Generator Pressure)

M01199803372 11B Service Water Plate Heat Exchanger Clean & Inspect I M01199803369 11 A Service Water Plate Heat Exchanger Clean & Inspect MOO 199s'01590 Spent Fuel Cask Transfer Preparation MO2199702282 Spent Fuel Pool Hoist Box Decontamination M01199803370 12 Service Water Plate Heat Exchanger Clean & Inspect b Observations and Findinas The inspectors found that the selected maintenance activities were 9rformed safely and in accordance with approved maintenance orders. Daily and weekly plant trip and core damage precursor risk assessments were completed for maintenance activities. Periods of higher risk were eliminated by revising the maintenance and testing sequence. For example, switchyard work was delayed during maintenance l on an auxiliary feedwater pump to minimize the risk of loss of offsite power when equipment used to mitigate this event was out of servic . _ _- _. .- __ _ , . _ .

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Due to the leak in the Unit 2 pressurizer level instrument nozzle weld (2-LT-110X), l the inspectors reviewed the maintenance rule status of the Unit 2 reactor coolant '

I system (RCS) pressure boundary. The leak did not exceed the system level criteria that would place the RCS pressure boundary in 10 CFR 50.65 a(1) status; however,

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the plant level criteria for equipment forced outage rate was exceeded. An issue

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report was written to document in the BGE corrective action system that the Unit 2 RCS pressure boundary function was moved to 10 CFR 50.65 a(1) statu l BGE experienced fouling of the newly installed service water heat exchangers. BGE intended that chemical treatment of the saltwater prior to entering the heat exchanger would limit fouling. As a result of the fouling, cleaning has been required to remove barnacles and marine growth on the saltwater side heat exchanger plates. The observed cleaning activities were performed using approved

, maintenance orders and vendor instructions. Pre-evolution briefs were performed and attended by all those individuals participating in the maintenance activit Foreign material exclusion considerations were implemented. Good communications were observed during the work. The inspectors observed that the heat exchanger chemical treatments had limited success and some unanticipated fouling of the heat exchanger surfaces was observed. As a result, additional cleaning of the heat exchangers was performed and BGE made adjustments to the chemical treatment frequenc Conclusions BGE conducted maintenance in an effective manner. Operational risk insights were effectively used in maintenance planning and schedulin The inspectors observed that the chemical treatment of the Unit 1 service water heat exchangers had limited success and unanticipated fouling of the heat exchanger surfaces was observed. As a result, additional cleanings of the heat exchangers were required and adjustments were made to the chemical treatment frequenc M1.2 Routine Surveillance Observations (IP 61726) Insoection Scope (61726)

The inspectors observed all or portions of the following surveillance tests:

STP-O-29 Unit 2 Control Element Assembly Partial Movement Test 01-30 Nuclear Instrument Calibration STP-O-5 Unit 1 Auxiliary Feedwater System Monthly Surveillance Test

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STP-O-8A 1 A EDG and 114kV Bus Testing -

STP-O-73C - Unit 1 Component Cooling Pumps Surveillance Test' i STP-M-171 - Unit 2 Containment Air Lock Test STP-0-73D Unit 2 Charging Pumps Surveillance Test -

STP-08A 2A Diesel Surveillance Test STP-088 . 1B Diesel Surveillance Test  :

STP-F-77 Test of the Diesel Fire Pump j

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The inspectors found that the selected surveillance activities were performed safely {

and in accordance with approved procedures. Test details were discussed at a pre- !

test briefing followed by a question and answer session. The sessions were ,

attended by all test participants and included clearly stated test expectations, past l problems, and industry experience. The test participants demonstrated good work i practices and good knowledge of their assigned responsibilities. Operations !

personnel demonstrated good peer-checking and independent verification practices !

when performing calculations and during the manipulation of switches and valve l Plant supervision provided active monitoring during testing. Applicable limiting !

conditions of operation (LCO) were entered and exited correctly in accordance with technical specifications. Test equipment was verified by the inspectors to be

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properly calibrated and sized according to the approved test procedures. When :

appropriate, testing sequence was coordinated with plant maintenance and j operations activities to minimize core damage risk and trip ris Conclusions

' The surveillance testing performed during this inspection period was completed in a :

well controlled manner with minimal risk. Plant supervision provided active >

monitoring during testin M8 Miscelleneous Maintenance issues (IP 92902)

l M8.1 (Closed) LER 50-318/96-01, Automatic Plant Trip Due to Partial Loss of Offsite -

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The LER described the circumstances of a partialloss of offsite power on Unit 2 caused by poor work coordination in the plant switchyard. During troubleshooting i of a switchyard breaker problem, a stuck breaker protection relay was inadvertently ,

activated, causing a partialloss of offsite power to Unit 2, a loss of forced I circulation on the reactor, and an automatic reactor trip on low reactor coolant flow, immediate corrective actions were discussed in NRC Inspection Report 50-  !

317&318/96-02. The inspectors verified that the short term and long term l

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. correct;ve actions discussed in the LER were completed. On a number of occasions, the inspectors observed briefings and work coordination for switchyard :

activities and verified that adequate controls were being used to prevent recurrence j of the problem. Procedural controls were developed and implemented to assure ;

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adequate oversight of switchyard work by non-nuclear division, BGE workers. BGE

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I actions in response to the reactor trip were appropriate. The LER is close M8.2 (Closed) LER 50-318/9P E Relays Out of Calibration Due to Bumped Dial l

The LER described an event where a undervoltage protection for a safety bus was ,

inadvertent ly made inoperable when a protective cover was installed upside down, j causing a setpoint dial to be bumped out of position. Another of the four channels l of undervoltage protection was being tested when the dial mispositioning was !

identified. As a result, two channels were inoperable for a period of .49 minutes and technical specification 3.0.3 was not entered, although no actions to initiate shutdown of the reactor were required for one hour. The inspector walked down the vital bus relays with the unit electrical supervisor and reviewed the corrective actions described in the LER. All of the technicians qualified to work on the ,

affected equipment were trained on the event and provided instructions to prevent !

recurrence. Also, actions to mark the relay covers and enhance procedures were in l progress at the time of this inspection. The inspector found the BGE actions in !

response to the event to be appropriate. The LER is close M8.3 Closure of Violations involving 1997 Fuel Handling Activities Inspection Scone The following fuel handling activity violations were reviewed. The violations were !'

documented in NRC Inspection Report 50-317&318/97-02 and responded to by a September 11,1997, BGE letter to the NR Violation EA06014, Corrective Actions for a Missing Capscrew  ;

Violation EA07014, Corrective Actions for Metallic Debris l Violation EA08014, Corrective Actions for a Failed Grapple Closed Light Violation EA09014, Corrective Actions for a Stuck Relief Valve on the Upender Violation EA10014, Corrective Actions for a Damaged CEA Cable l Violation EA11014, Failure to Follow Procedures Regarding Spent Fuel Pool Ventilation Findinas and Observations The inspector verified through discussio.1s with the BGE refueling system manager that a process to conduct material condition inspections and testing of refueling equipment, prior to each refueling outage, had been implemented. The process included either a video camera inspection or a diver inspection of equipment not normally accessible from the refueling floor. Also, BGE had emphasized the material condition of refueling equipment in maintenance plannin .

As discussed in NRC Inspection Report 50-317&318/98-06, the inspectors observed fuel handling activities during the 1998 refueling outage of Unit 1, during which a complete core off-load and reload were completed. Overall, the conduct of the fuel handling was good and no significant fuel handling equipment or procedure problems were observe Conclusions 1 i

The inspectors found the BGE actions regarding each violation to be acceptable and !

each issue is close M8.4 (Closed) Violation 50-317&318/96-10-04, Incomplete Corrective Actions for l Electrical Separation Barriers

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The violation involved a failure to update design documents and fourteen examples where the as-built configurations for electrical separation did not meet design criteria due to missing or damaged separation barriers. As corrective action, BGE assigned responsibility for electrical separation to a system engineer who )

implemented a plan for regular walkdowns of system components to identify i deficient electrical separation conditions. A list of allidentified deficiencies, )

including the apparent cause and corrective action taken was used by the engineer j to track and resolve problems. The inspector verified that operations and i maintenance personnel had been trained on electrical separation methods to identify - !

problems and prevent inadvertent damage to separation materials. Following the j 1998 refueling outage on Unit 1 and at other times, the inspectors have conducted l walkdowns to assess electrical separation and no problems were identified. The BGE actions were determined to be appropriate and the violation is close M8.5 (Closed) LER 50-317/97-09, Automatic Reactor Trip Due to Condenser Vacuum Breaker Opening The LER described the circumstances of the Unit 1 automatic trip on low condeneer vacuum when a condenser vacuum breaker unexpectedly opened. The condenser vacuum breaker opening was caused by a failure to properly terminate a non-safety ,

related electrical lead on the condenser vacuum breaker hand switch during I maintenance, immediate corrective actions were discussed in NRC Inspection Report 50-317&318/97-06. The inspectors verified that the long term corrective actions discussed in the LER were completed. A BGE significant issue finding team

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d been created to determine the cause of the event and formulate corrective actions to prevent recurrence. Approximately 200 connections on similar switches in the Unit 1 control room were inspected and no similar deficiencies were identified. A thorough and detailed root cause analysis was completed. A review of records verified that maintenance personnel were provided training on the event details and the importance of self-checking during maintenance. The BGE actions were appropriate and the LER is close .

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M8.6 (Closed) LER 50-317&318/98-02, Fire Hose Stations and Room Sprinkler Systems Out-of-Service ,

The LER described the circumstances of fire hose stations and room sprinkler systems in the Auxiliary Building that were discovered out of service with no ;

compensatory actions established. Due to a previously undiscovered valve labeling 1 error, an incorrect valve had been shut while establishing the tagout boundary. The 1 inadvertently isolated components were returned to service within approximately 35 minutes. BGE performed an appropriate root cause analysis of the event and determined that a mislabeled valve had been operated. BGE identified the problem and completed the corrective actinns for this event prior to submitting the LER. The completed corrective actions included correcting the incorrect valve label, and performing a walkdown of selected accessible portions of the fire water systems to verify that the drawings and valve labels were correct. The isolation of the incorrect valve in establishing the tagout boundary was a failure of minor safety significance and was not subject to formal NRC enforcement action. The LER is close M8.7 (Closed) Violation 50-317&318/97-05-02, Inadequate Corrective Actions for Problems identified with Compression Fittings The violation was cited when BGE did not promptly identify and correct problems with the installation of compression fittings used in plant systems. The specific event involved a fitting that had been improperly installed in 1996 on a pressurizer instrument line which had failed on May 29,1997. BGE responded to the Notice of Violation by letter, dated November 10,1997. The response noted that the ;

immediate corrective actions had been discussed in LER 317/97-005. The LER was )

closed by the inspectors in NRC Inspection Report 97-05. The inspectors observed-that the BGE root cause report was thorough and comprehensive. The inspectors reviewed a sample of the corrective action recommendations and determined that i the recommendations were properly dispositioned. Additionally, BGE performed an l effectiveness review for the corrective actions taken. In the r.kie months after the corrective action implementation,170 maintenance orhrs involving tubing and compression fittings were performed. No examples o) tubing or fitting type failures were identified. The BGE actions in response to the vio!stion were appropriate and the violation is close ;

111. Enaineerina E2 Engineering Support of Facilities and Equipment (IP 37551)

E Moisture Separator Vant Piping Failure Inspection Scope The inspectors reviewed the BGE corrective actions following a vent piping failure on Unit 2.

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b. Findinas and Observations Following the Unit 2 moisture separator vent line piping failure (See 0.2), BGE assembled an engineering team to determine the root cause and recommend corrective actions. The team determined that the rupture was the result of flow accelerated corrosion (FAC) of two-inch, carbon steel piping downstream of an elbow in a high pressure to lower pressure steam vent. An inspection of the failed segment showed thinning of the piping in the vicinity of the failur The BGE engineering reviewed the approximate 3700 small bore (less than or equal to two-inch) and large bore (greater than two-inch) piping inspection points in the FAC program for Unit 2. Since the inception of the BGE FAC program, there were about 830 small bore inspections; however, there remained about 800 points that had never been inspected. Points were not inspected because of engineering i judgement that failure of the piping at that location would: 1) not directly cause a i reactor trip; 2) would not present a personnel hazard; or 3) would not otherwise present safety consequences. The engineering judgement also included an expectation that the piping would exhibit a smallleak before a catastrophic f ailure, as had been the general BGE experience with small bore piping. The piping failure did not directly effect plant operating parameters; however, it could have posed a personnel safety hazard had an individual been in the vicinity of the pipe at the time of the failur As part of the investigation, BGE reviewed all of the 800 points that had not been inspected and screened each point for immediate inspection. Of the 800 points, over fifty points were examined to check for FAC. One of these examinations revealed a point where the wall thickness was below an allowable minimum valu This point was'in the same line as the failure and the entire piping s'egment was replaced with a Chrome-Molybdenum alloy that is not susceptible to the observed corrosion mechanis The BGE review team also evaluated Unit 1 and found that moisture separator configurations similar to the failed piping did not exist. BGE intended to complete a review of the large bore piping program on both Units 1 and 2. BGE informed the inspectors that following completion of the BGE engineering review, an independent review of the BGE erosion corrosion program would be conducte Conclusions BGE erosion corrosion engineering personnel erred in judging that some piping segments in the Unit 2 steam plant were not susceptible to catastrophic failure due l- to flow accelerated corrosion. The result was a piping failure that led operators to manually trip Unit 2. The BGE engineering review of the failure was extensive and included examinations of piping and review of program assumptions. Some piping segments in the Unit 2 steam plant were replaced with alloy piping material not susceptible to flow accelerated corrosion prior to Unit 2 restar ,

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E2.2 (Closed) LER 50 318/98-005, Plant Cooldown Due to Reactor Coolant System Pressure Boundary Lenkage i

1 Ipsoection Scooe (37551) '

I The inspectors BGE response to the identification of a reactor coolant pressure )

boundary leak at the pressurizer level instrument reference leg. BGE summarized their actions in the LE I Findinos and Observations On July 25,1998, with Unit 2 in Mode 3 (Hot Standby), a steam leak was discovered at the upper level tap on the pressurizer (See 01.2). BGE promptly placed the unit in Mode 5 (Cold Shutdown). BGE engineering personnel took immediate action to develop a repair plan for the breached primary boundary once i the plant was cooled down and depressurized to allow physicalinspection. A project team was assembled and led by the reactor coolant system manager. A clear and concise written plan was produced by the system manager and as a l result, the applicable maintenance orders and special work permits were generated I expeditiously. Safety considerations were observed by engineering and clear communications with the operations department were noted. Good coordination between BGE engineering and a contracted repair company was observe The LER documented the immediate corrective actions taken by BGE. The corrective actions included: performing various nondestructive tests (NDT) including a dye-penetrant test of the inside of the penetration sleeve, an ultrasonic test of the pressurizer shell around the penetration, and a remote interior visual inspection of the penetration weld. BGE also visually inspected three other upper level nozzles and found no evidence of leakage. Based on the results of these actions, BGE engineering personnel concluded that the pressure boundary failure was an isolated occurrence of primary water stress corrosion cracking (PWSCC). The LER described the corrective action repairs that included a BGE engineering plan which removed i the outer portion of the leaking nozzle followed by the installation of a weld pad '

around the penetration area where a new nozzle was inserted. The new nozzle was welded to the weld pad using an Alloy 690-type filler material that is not susceptible to PWSC l In a letter dated August 4,1998, BGE submitted the results of the flaw evaluation to the NRC Office of Nuclear Reactor Regulation for review as required by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Cod l In a follow-up letter dated August 25,1998, BGE committed to prepare an action plan for further inspection of the Unit 2 pressurizer instrument nozzle weld flaw by February 26,199 l l

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12 I Conclusions i

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.BGE engineering personnel were very effective in their involvement and responsiveness to the identification of the pressurizer leak. BGE took the required ,

engineering measures to diagnose, repair, and document the leaking pressurizer !

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weld. The corrective actions identified in the LER were appropriate in scope and ,

l detail. The inspectors verified that these corrective actions were acceptably ;

I completed. The LER is close '

E2.3 Structure and System Walkdowns

[ ' Insoection Scoos l'

l The inspectors observed p! ant engineers conduct walkdowns of various safety l related structures and systems, Findinas and Observations The direction for performing structure and system walkdowns by engineering personnel was provided in BGE administrative procedure' MN-1-319, Structure and System Walkdowns. The requirements for reporting identified deficiencies were l provided in this procedure as well as a process for evaluation of material condition

[ in accordance with 10 CFR 50.65. The procedure specified that the intervals and extent of the periodic walkdowns were to be negotiated between the system l

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engineer and the applicable principal engineer.

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Based on discussions with a sample of the principal engineers, the inspector fo md p that the results of these negotiations are not documented; however, the principal j engineers had informally established expectations that portions of systems would be l walked down monthly and that all the accessible portions would be walked down at i least quarterl The inspectors observed walkdowns conducted by engineers responsible for the SACM and Fairbanks Morse emergency diesel generators (EDG) and the emergency core cooling systems. The inspectors observed walkdowns of selected portions of the emergency diesel generator, containment spray, low pressure safety injection, and high pressure safety injection systems. Each of the system engineers '

performed thorough and competent walkdowns using general checklists provided in ;

MN-1-319 as guidance. The system engineers were knowledgeable of the '

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outstanding system deficiencies and the impact of the deficiencies on operational

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safety.

The system engineers appeared to have a low threshold for identifying and j recording new potential problems. The engineers indicated that accessible portions

! of their systems were walked down on a monthly basis and inaccessible portions l- were walked down during outages. Discussions with the EDG system engineers indicated that less formal weekly walkdowns normally were performed in addition to the normal monthly walkdown. The inspector noted that the SACM EDG system

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engineer recorded specific system parameters for trending purposes. The inspector

. also noted that the EDG system engineers had provided support and oversight during surveillance testing of the EDG Conclusions The inspectors observed BGE system engineers conduct structure and system walkdowns and concluded that thorough and competent engineering walkdowns were routinely performed. The system engineers were knowledgeable of the outstanding system deficiencies and the impact of the deficiencies on operational safety. The system engineers had a low threshold for identifying and recording new potential problems. The EDG system engineers trended system parameters and provided good support during surveillance testing of the EDG E8 Miscellaneous Engineering issues (IP 92903)

E (Closed) Violation 50-317&318/96-10-02, Failure to Support Dry Fuel Cask Unloading The violation involved a failure of the BGE dry fuel storage canister unloading procedures to include detailed instructions to assure that cask overpressurization w'.,uld be prevented during reflood operations. In the BGE response to the violation dated April 4,1997, BGE committed to complete a detailed calculation to bound the reflood ra+ i of the canister, to do a root cause evaluation of the event, and to incorpora i C L 'ssons learned into the cask unloading procedure. The inspector i verif.. -' % rough discussions with BGE fuels engineers and review of the root cause evaluation that tha actions had been completed. The inspector also verified that the cask unloading procedure had been revised to include cask specific over- :

pressurization preventive measures. The BGE actions in response to the violation l were appropriate and the violation is close !

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E8.2 (Closed) Licensee Event Report 50-317/98-03; Technical Specification Violation, Low Pressure Safety injection Inoperable This LER documented the discovery and resolution of damage to restraining steel (pipe support) in the Unit 1 low pressure safety injection (LPSI) system common header piping (reference Inspection Report 50-317&318/98-80,section E2.2). The damage was attributed to water hammer caused by recurring check valve sla The inspector walked down the affected piping with a system engineer and l reviewed the BGE corrective actions. The inspector determined that the damaged pipe supports had previously been evaluated, as documented in an engineering evaluation complete following a 1989 water hammer event. This evaluation included a series of stress calculations which provided a basis for removal of a number of pipe supports, including R-2 in the LPSI suction header and R-16 in the discharge heade _

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A root cause evaluation was completed to address this recent discovery and a number of corrective actions were specified, including: training of operations

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personnel on water hammer events; repair of the affected supports; and the planned l substitution of the LPSI discharge check valves with a design less susceptible to l check valve slam. In addition, filling, venting, and flushing procedures had been l implemented at Unit 1 and were being implemented at Unit 2 to minimize the amount of air that could accumulate in the system piping following maintenanc BGE identified that corrective actions following 1987 and 1989 LPSI system watet hammer events were not totally effective in preventing recurrence. The inspect determined that this contributing cause was being separately addressed in the BGE corrective action process. The inspector concluded that BGE's corrective actions

for this event were appropriate. This LER is close IV. Plant Suonort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Backshift Observation of Radiological Protection Controls and Activities Scope The inspectors observed various radiological protection activities during the Unit 2 shutdown to repair a pressurizer leak.

Observations and Findinas l During the Unit 2 forced outage, the inspectors observed radiological controlled area (RCA) access, pre-job briefings, and job coverage by radiation safety technicians (RST). . The inspectors observed that workers stopped at the RCA entrance to L discuss their jobs, the special work permit (SWP) controls, and additional radiation l

safety instructions with the special work permit coordinator (SWPC). The

, inspectors also noted that a BGE management expectation for workers and the

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SWPC to use three-way communications for RCA access check-in had been implemente The inspectors observed selected pre-job briefings for work that was being done to prepare. for the replacement of a pressurizer instrument nozzle. Both the maintenans mpervisor and the RST used pre-job briefing checklists. Topics

[. discussed at the briefing included the evolution objective, roles and responsibilities, l specific radiological controls, current radiological conditions, and strategies to be used to improve human performance. The personnel attending the briefs were

! attentive and demonstrated questioning attitudes. Minor deficiencies identified by the inspectors were promptly analyzed and resolved.

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15 The inspectors also accompanied a group of workers on a containment entry to perform preparations for replacing a Unit 2 pressurizer instrument nozzle. The RST verified that the _ workers were properly wearing the specified protective clothing, dosimetry, and air sampling equipment. The RST provided appropriate support for

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the work including radiological surveys, air sampling, and monitoring of worker practices and exposur l Conclusions BGE appropriately condt.cted radiological protection activities during a Unit 2 forced outage. The observed RCA access check-ins were conducted in an acceptable j

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manner and three-way cornmunications were used. Pre-job briefings were thorough and comprehensive and the participants demonstrated good questioning attitude The RST provided good job coverage including radiological surveys and effective worker monitorin l

R7 Quality Assurance in Radiological Protection & Chemistry (RP&C) Activities (IP 92904)

R7.1 (Closed) LER 50-318/97-003; Chemistry Sampling Not Performed as Required by Technical Specifications Scooe (92700)

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l The inspectors reviewed LER 50-318/97-003 that described problems with Unit 2 '

l reactor coolant system (RCS) chemistry samplin I i

! Observations and Findinas

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On April 22,1997, BGE identified that Unit 2 RCS samples required to be tr. ken to I comply with Technical Specification (TS) 3.4.7, " Reactor Coolant System )

Chemistry" had not been taken. Samples were not taken after the reactor had been l defueled on April 11 and subsequently drained. Calvert Cliffs Technical Specification Surveillance Requirement 4.4.7 was applicable at all times and required that RCS samples be analyzed for chlorides and fluorides every 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Action statements were stipulated for excess halogen concentrations found with the unit in Modes 1 through 6. Chemistry personnelinterpreted this as meaning that samples were only to be taken in Modes 1 through 6. There was no capability to sample once the RCS was draine Upon discovery, BGE entered the issue in their corrective action process. The BGE l corrective actions included: (1) taking samples as soon as practicable upon discovery that the sampling was required; (2) clarification of the existing technical specification was planned after the Improved Technical Specifications (ITS) were

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implemented; and, (3) BGE management re-emphasized the expectation that technical specifications were to be implemented as written. A site-wide review was planned to determine if there were any other technical specifications being inappropriately interpreted.

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The LER stated that the samples taken after discovery of the oversight, were found to be within acceptable limits. The inspectors reviewed the records of RCS chemistry samples taken during the refueling and defueled periods of the Unit 1 1998 refueling outage and found that BGE performed the surveillances required by TS 4.4.7. These RCS chemistry requirements were removed from TS 3.4.7 and relocated to Updated Safety Analysis Report Chapter 15, Technical Requirements Manual (TRM) by the implementation of the improved technical specification However, the problem had not been corrected because sampling continued to be ,

required by the technical requirements with the RCS drained. BGE informed the i inspectors that this problem would be corrected prior to attaining that conditio !

The inspectors considered this issue to be of minor safety significanc l Chemistry personnel evaluated requirements for chemistry parameters and surveillances to ensure that all actions required could be performed as stated in the

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applicability section of technical specifications. The BGE investigation did not identify any additional areas where the TS were not being performed as state Also, the Superintendent of Nuclear Operations requested the Nuclear Performance Assessment Department (NPAD) perform a review of operating practices. The review included: operator training on technical specification, implementation of technical specifications, and the TS interpretations. The NPAD assessment did not identify any issues; however, several recommendations were generated. An inspector review of the BGE action item tracking system confirmed that BGE took action on these recommendation Conclusions The inspectors found that BGE LER 50-318/97-03 was timely, accurate, and appropriately described the event. The corrective actions identified in the LER had been completed. Additional corrective actions identified in BGE follow-up activities were appropriate and had been implemented or were scheduled. The issues raised in the LER were of minor safety significance. This LER is close R7.2 (Closed) Violation 97-03-01; Multiple Examples of Failure to Document and Report to Management Significant Conditions Adverse to Quality The violation was cited for three radiation protection area events that had not been i documented in the BGE issue report system although they had met the BGE established documentation criteria. The inspector verified through discussions with radiation safety personnel that awareness of the need to document problems in the issue report system had become a radiation safety management expectatio Further, the inspector observed that there was a marked increase in issue reports in the area, commensurate with problems that were being identified following an event on April 9,1998, as discussed in NRC Inspection Report 50-317&318/98-0 Subsequent to that event, BGE had taken actions to improve radiation safety performance, including careful documentation of problems and tracking of corrective actions. BGE actions in response to the violation were appiopriate, including

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review of concerns to ensure proper documentation in the corrective action process i and awareness training of line radiation safety personnel. The violation is close P2 Status of EP Facilities, Equipment and Resources i j P Severe Weather Communications Capabilities

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-The inspectors reviewed the BGE emergency preparedness communications capability and discussed severe weather conditions communications with BGE telecommunications and emergency planning personnel. BGE maintained communication capabilities with off-site agencies using radio, microwave, and redundant underground telephone equipment, in the event that severe winds render all above ground communication systems inoperable, the dedicated underground telephone trunks were maintained, each with an emergency power supply. The inspectors concluded that BGE would be able to maintain a communication line with off-site agencies following severe weather condition P3 EP Procedures and Documentation P Emergency Rc:;panse Plan Changes The inspectors reviewed several changes BGE made to the emergency response plan (ERP) and its associated implementing procedures (ERPIPs). The inspectors verified that the changes to the documents reviewed did not decrease the overall effectiveness of the emergency response plan, met the standards of 10 CFR 50.47(b), and met the requirements of Appendix E to 10 CFR Part 50. A list of ERP and ERPIP changes reviewed is included as an attachment to this repor l

P4 Staff Knowledge and Performance in EP (IP 82206)  !

l P Radiological Assessment Capability 1 i Insoection Scone (82206) l The inspectors observed, in prescripted scenarios, the performance of emergency personnel responsible for radiological assessment during emergencie Observations and Findinas Individual performance of four on-shift chemistry technicians in a static control room simulator environment were assessed along with the performance of four (l radiological assessment specialists and two radiological assessment directors l functioning in two separate teams in the emergency operations facility.

l The chemistry technicians generally performed their duties in the scenarios without

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error. Some scenarios included changes in wind direction between calculations and

others required manual dose assessment calculations to be completed. One i

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technician made two errors when performing a manual calculation. Another took an i

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excessively long time to perform calculations for one scenario using the BGE radiological assessment computer model. Two of the technicians made errors in calculations which they later self-identified and corrected before any adverse consequences would have resulted. Allindividuals interacted with their shift managers to understand the nature of the simulated radiological accident and to convey recommendation l The BGE radiological assessment teams in the emergency operations facility also performed their duties wellin the observed scenarios. Occasional mistakes were made by the radiological assessment specialists, but except for one case these were self-identified and corrected without outside prompting. The radiological assessment specialists were familiar with the use of procedures for determining accident type. They were able to continue performance of their duties during simulated absences of the radiological assessment directors, and they questioned the validity of incongruous incoming dat The BGE radiological assessment directors were very familiar with their duties, procedures, computer model capabilities, and dose assessment concepts. The directors effectively led their teams to formulate timely and accurate real time assessments and projected forecast All of the BGE chemistry technicians interviewed, indicated that they considered the revised procedure that governs their emergency tasks to be an improvement. The technicians stated that they felt that there was room for further improvement in the procedure. For example, one technician who was interviewed felt that the procedure should provide better transition to the other procedures that may need to be used to perform the on-shift radiological assessment task. The inspectors discussed this finding with emergency planning unit (EPU) and training personne These personnel stated that further procedural enhancements had been identified and were planned as a result of observation of the scenario Conclusions The performances of the on-shift interim and long term augmentation radiological assessment staffs were much improved over previous observations. The procedure improvements made since the last NRC inspection effectively improved performance, but further procedure improvement was needed to address concerns raised by the procedure users during simulated scenario P5 Staff Training and Qualification in EP (IP 82206)

P5.1 Evaluation of Emergency Preparedness Training

! Inspection Scope (82701)

The inspectors monitored two training classes to evaluate the conduct of trainin They interviewed several individuals responsible for providing emergency response organization (ERO) training to determine the EPU's oversight of the training program.

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Finally, they reviewed documents governing the conduct of ERO member training to l assess the training program implementatio Observations and Findinas l

l The designated objectives and topics for basic emergency response training and self contained breathing apparatus (SCBA) training were appropriately covered and trainee handouts were informative and aided the training process. The training was provided at the appropriate level for the attendees. During SCBA training, there was a strong emphasis by the instructnr on personr.el safet Interviews with those responsible for providing ERO training indicated a change in the EPU's oversight of the training program. Training providers described their past working relationship with the EPU as informal. Communications with the EPU was generally driven by personnel initiative instead of programmatic controls. Recently, the EPU has been more involved in the training program. For example, the EPU had reviewed lesson plans and examinations. The EPU revised ERPIP-904, Emergency Response Training, to more clearly define EPU and trainer responsibilities. The training providers interviewed were aware of the revision to ERPIP-90 The inspectors identified one discrepancy in the conduct of EP training. ERPIP-904 stated the t the EPU was responsible for " evaluating training effectiveness and l additional training needs." ERPIP-904 also stated that " trainees are primarily l evaluated by drill performance." Based upon reviews of the emergency response plan, ERPIP-904, SOP-20 (Emergency Response Training Program), and the recently superseded Emergency Response Training Program Manual, there was no specific requirement for written examinations or drill participation for ERO requalificatio Therefore, there were no programmatic controls to ensure that the above mentioned

, evaluations were performed. The inspectors were informed that some ERO j members received a written examination upon completion of their requalification l training and that ERO members participated in drills based upon their assigned j position. The EP Director (EPD) stated that individual drill participation had not been l tracked in the past although drill attendance sheets were available. He had recently l initiated action to begin tracking individual drill participation in a data base. The l EPD stated he was considering action which could specify the requalification

! training evaluation requirements to ensure that the statements in ERPIP-904, as i stated above, were me c. Conclusions The inspectors concluded that training was being conducted as specified in the emergency response plan and that the EPU was exercising closer oversight of ERO training. The BGE procedures did not adequately specify how to evaluate or track personnel performance in order to evaluate the effectiveness of EP requalification training.

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P6 EP Organization and Administration (IP 82701)

l P6.1 Emergency Response Organization Readiness a. Insoection Scope (82205)

The licensee briefed the inspectors on its recent initiative for more effectively tracking the ERO's ability to respond in a timely manner to plant emergencies. The inspectors reviewed the BGE self-assessment leading to this initiative and the documentation of the recently performed personnel notification test Observations and Findinas BGE formerly tracked ERO personnel response times by conducting a recall drill every six years. After conducting a self-assessment of the adequacy of this practice for ensuring complete and timely response, BGE instituted a quarterly personnel notification test to verify that regulated positions in the ERO could readily be filled. The test solicited and recorded the estimated response time of each respondent. BGE incorporated this test into its preventive maintenance schedule and revised its standard operating procedure to describe the proces Conclusions The BGE initiative to more formally track and verify emergency personnel response from offsite was considered an appropriate program enhancemen P8 Miscellaneous EP issues (IP 92904)

P8.1 (Closed) Inspector Follow-Up item 50-317&318/97-09-01 The BGE dose assessment staff at the EOF could not use the on-line dose assessment code to provide an accurate protective action recommendation. This item was opened to track BGE corrective actions for an exercise weakness observed during the November 18,1997 biennial EP exercise. The inspectors noted that the following corrective actions were either completed or planned for completion in the near future:

• Completion of special one-on-one training given to radiological assessment specialists

• Completion of assessment drills conducted on July 2, and August 13,1998

• Completion of formal group training on August 10,11,1998

• Completion of a formal Job Task Analysis for radiological assessment

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directors and specialists (results pending at the completion of the inspection)

• Planned personnel reassignments in the above two positions to strengthen l

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performance l * Planned procedure upgrades for the above two positions l

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I Based on the above corrective actions and the favorable performance by the two f dose assessment staffs observed, the inspectors considered the BGE correction of  !

the exercise weakness to be adequate. This item is close !

l P8.2 (Closed) Inspector Follow-Up item 50-317&318/97-08-04 l l

The concern was written to follow-up on BGE actions to identify and protect 1 technical support center (TSC) responders from thyroid exposure during accidents, j BGE had performed an initial screening of all TSC responders to determine if they  ;

were:

• allergic to potassium iodide (KI) thyroid blocking agent

• willing to ingest Kl if it were provided to them

• qualified in the use of self-contained breathing apparatus (SCBA)

• physically able to wear an SCBA Based on the responses to the above questions, BGE determined that all of its TSC responders would be protected in the event of a radiological accident resulting in large radiolodine concentrations in the TSC. BGE also formalized the above questionnaire into a recurring task that was entered into the EPU's task tracking system. The inspectors concluded that the actions were appropriate. This item is close P8.3 (Closed) Violation 50-317&318/97-08-05; Failure to Test Communication Circuit The violation resulted from the failure of BGE to test communication circuits in accordance with Part 50, Appendix E. BGE completed the following actions that were committed to at the time of the January 1998 inspection as well as a February 2,1998 meeting at the NRC Region I office. These included:

• the reinstatement of monthly testing requirements for the circuits in question

• the resumption of tracking the communication surveillances by the EPU

• the addition of a step to the EPU task tracking schedule to evaluate changes to that schedule for potential decreases of effectiveness of the emergency plan

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Based on satisfactory completion of the above actions, this violation is close l

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P8.4 (Closed) Violation 50-317&318/97-08-06; Training Deficiencies in Dose Assessment Capability

The violation was issued due to training deficiencies in on-shift dose assessment j and the use of an automated dose assessment model. BGE completed all actions l

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committed to in its April 20,1998 response to the Notice of Violation. These ,

! included additional training and evaluation of the interim radiological assessment l l directors (lRADs) as well as upgrading of the ERPIP for the IRADs. The inspectors )

l considered the BGE actions adequate and the performance of the IRADs in the i observed scenarios favorable (see section P4). This violation is close l i

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22 y. Maneaement Meetinas X1 Exit Meeting Summary l

During this inspection, periodic meetings were held with station management to l discuss inspection observations and findings. On October 1,1998, an exit meeting i was held to summarize the conclusions of the inspection. BGE maner,ement in l attendance acknowledged the findings presente X2 Review of UFSAR Commitments While performing the inspections discussed in this report, the inspectors reviewed the applicable UFSAR sections that related to the areas inspected to verify that the !

UFSAR wording was consistent with the observed plant practices, procedures, I and/or parameters. No discrepancies were identifie i l

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h ATTACHMENT l

l PARTIAL LIST OF PERSONS CONTACTED

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i D.GE

. C. Cruse, Vice President- Nuclear Energy Division

. P. Katz, Plant General Manager L. Wechbaugh, Superintendent, Nuclear Maintenance 1 L M.Navin, Superintendent, Nuclear Operations l K. Neitmann, Manager, Quality Assurance '

! B. Montgomery, Director, Nuclear Regulatory Matters

.. S. Sanders, General Supervisor, Radiation Safety T. Sydnor, General Supervisor, Plant Engineering D. Holm, General Supervisor, Plant Operations  !

T. Pritchett, Superintendent, Technical Support  !

T. Forgette, Director, Emergency Planning Unit J, l_emons, Manager, Nuclear Support Services .

INSPECTION PROCEDURES USED i

IP 61726: Surveillance Observations IP 62707: Maintenance Observation

. IP 71707

Plent Operations l lP 92700: Onsite Follow up of Written Reports of Nonroutine Events at Power Reactor

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Facilities l l IP 73755 Inservice inspection - Data Review and Evaluation

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IP 37551 Onsite Engineering

. IP 71750 Plant Support Activities '

IP 82205: . Shift Staffing and Augmentation .

L IP 82206: Knowledge and Performance of Duties'(Training)

IP 82701: Operational Status of the Emergency Preparedness Program  !

IP 92904: Follow-Up: Plant Support l

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Attachment 1 2 ITEMS OPENED, CLOSED AND DISCUSSED [

Open i

None ,

Closed '

50-318/96-01 LER Automatic Plant Trip Due to Partial Loss of Offsite Power 50-318/98-004 LER Manual Plant Trip Due to Moisture Separator Reheater Vent Line Rupture <

50-318/98-03 LER Relays Out of Calibration Due to Bumped Dial i 50-317&318/96-10-01 VIO Failure to Assure Fuel Handling Procedures Were  ;

1 Adequate .

50-317&318/96-10-02 VIO Failure to Support Dry Fuel Cask Unloading i EA 97-192-06014 VIO Corrective Actions for a Missing Capscrew j

- EA 97-192-07014 VIO Corrective Actions for Metallic Debris EA 97-192-08014 VIO Corrective Actions for a Failed Grapple Closed Light  ;

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EA 97-192-09014 VIO Corrective Actions for a Stuck Relief Valve on the i Upender  !

l EA 97-192-10014 VIO Corrective Actions for a Damaged CEA Cable

! EA 97-192-11014 VIO Failure to Follow Procedures Regarding Spent Fuel Pool Ventilation j 50-317&318/96-10-04 VIO Incomplete Corrective Actions for Electrical Separation l .

Barriers /97-09 LER Automatic Reactor Trip Due to Condenser Vacuum l Breaker Opening

! 50-317&318/98-02 LER Fire Hose Stations and Room Sprinkler Systems Out-of-Service 50-317&318/97-05 uz VIO Inadequate Corrective Actions for Problems identified with the Installation of Compression Fittings 50-318/98-005 LER Plant Cooldown Due to Reactor Coolant System L

Pressure Boundary Leakage 50-317/98-03 LER Technical Specification Violation, Low Pressure Safety injection Inoperable 50-318/97-003 LER Chemistry Sampling Not Performed as Required by Technical Specifications 50-317&318/97-03-01 VIO Multiple Examples of Failure to Document and Report to Management Significant Conditions Adverse to Quality 50-317&318/97-08-04 IFl Follow up on licensee actions te identify and protect j l

! TSC responders from thyroid exposure during accidents

! 50-317&318/97-08-05 VIO Failure to test communication circuits in accordance

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with Part 50

• 50-317&318/97-08-06 VIO Training deficiencies in on-shift dose assessment staff ,

use of automated dose assessment model J 50-317&318/97-09-01 IFl The dose assessment staff at the EOF could not use the on-line dose assessment code to provide an accurate

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protective action recommendation 2-l

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I Attachment 1 3 LIST OF ACRONYMS USED )

ASME American Society of Mechanical Engineers CEA Control Element Assembly (Control rod)

CS Containment Spray EDG Emergency Diesel Generator EOF Emergency Operations Facilities EP Emergency Planning .

EPD Emergency Planning Director EPRI Electric Power Research Institute EPU Emergency Planning Unit ERO Emergency Response organization ERP Emergency Response Plan i ERPIP Emergency Response Plan implementing Procedure l FAC Flow Accelerated Corrosion FME Foreign Material Exclusion HPSI High Pressure Safety injection l IRAD Interim Radiological Assessment Director ISTS/ITS Improved Standard Technical Specifications Kl Potassium lodide LCO Technical Specification Limiting Conditions of Operation LER Licensee Event Report LPSI Low Pressure Safety injection NDT Nondestructive Tests NOV Notice of Violation i NPAD BGE Nuclear Performance Assessment Department '

PDR NRC Public Document Room PWSCC Primary Water Stress-Corrosion Cracking ,

RCA Radiological Controlled Area '

RCS Reactor Coolant System RST Radiation Safety Technician SACM diesel manufacturer acronym SCBA Self Contained Breathing Apparatus SWP Special (radiation) Work Permit SWPC Special Work Permit Coordinator TRM Technical Requirements Manual TS Technical Specification TSC Technical Support Center UFSAR Updated Final Safety Analysis Review l

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Attachment 1 4 Emergency Response Plan and implementing Procedures Reviewed

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DOCUMENT DOCUMENT TITLE REVISION N / CHANGE N l EAL-BASIS Emergency Action Levels Basis Document 6/0 ERP Emergency Response Plan 25/0 ERPIP Immediate Actions 19/0, 20/0, !

21/0 l l

ERPIP-102 Superintendent-Nuclear Operations 2/1, 3/0 l ERPIP-105 Control Room Communicator 3/5,4/0 ;

ERPIP-106 Plant Parameters Communications-Control Room O/1 ERPIP-107 Interim Radiological Assessment 2/1,3/0 ERPIP-108 Interim Radiation Protection 1/0 ERPIP-202 Plant General Manager 2/2,3/0 ERPIP-209 Technical Support Center Communicator 3/4 !

ERPIP-303 Radiation Protection Director 2/0 i

ERPIP-314 Operational Support Center Communicator 1/1 ERPIP-315 Plant Parameters Communications-OSC 0/5 ERPIP-318 Onsite Monitoring Team Members 1/1 I ERPIP-501 Site Emergency Coordinator 3/1,4/O ERPIP-E09 Emergency Operations Facility Communicator 3/4 ERPlF-511 Radiological Assessment Director 2/O ERPIP-750 Security 5/0 ERPIP-822 Initial Dose Assessment Manual Calculation Methods 2/0 ERPlP-824 Dose Assessment Reference 1/0 ERPIP-832 Emergency Work Permits 3/O ERPIP-901 -Communications Equipment 2/2 ERPlP-902 Records  %

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I Attachment l ' 5 l

ERPIP-903 Monitoring Equipment'and Instrumentation 1/0 i ERPIP-904 Training 3/0 l

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i ERPIP-905 Exercises, Tests and Drills 3/0 ERPIP-B.1 ' Equipment Checklist 20/0, 21/0

ERPIP- Off-site Survey Points 10/0 i

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