IR 05000317/1979007

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IE Insp Repts 50-317/79-07 & 50-318/79-06 on 790501-11. Noncompliance Noted:Failure to Follow Procedures in Areas Involving Valve Positioning & Positive Control
ML19209C193
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 08/06/1979
From: Blumberg N, Dante Johnson, Keimig R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19209C187 List:
References
50-317-79-07, 50-317-79-7, 50-318-79-06, 50-318-79-6, NUDOCS 7910120178
Download: ML19209C193 (18)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-317/79-07 50-318/79-06 Docket No. 50-317 50-318 License No. DPR-53 Priority:

Category:

C

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DPR-69 C

Licensee:

Baltimore Gas and Electric Company P. O. Box 1475 Baltimore, Maryland 21203 Facility Name:

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection at:

Lusby, Maryland Inspection condu ed:

Ma 1-11, 1979 S-b-79 Inspectors:

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m 8-601 N. J. ' BTUnbe

,R ctor/nspector date signed Approved by:

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b[-7f R. Y. Kdimig, Chief Reacpr Projects date signed Section No. 1, R0&NS Beatch Inspaction Sumary:

Inspection on May 1-4 and 7-11, 1979 (Report Nos. 50-317/79-07, 50-318/79-06)

Areas Inspected:

Routine, unannounced inspection to verify the actions required by IE Bulletins 79-06 and 79-06B.

Specific areas of review included:

operator training and assessment of operating procedures; valve / breaker / switch alignment procedures for Engineered Safety Features (ESF); verification of valve / breaker / switch alignment for ESF; system operability following maintenance; plant surveillance test procedures and test results; ESF operability following extended outages; licensee utilization of independent verification; auxiliary feedwater system operability; and facility tours.

The inspection involved 89 hours0.00103 days <br />0.0247 hours <br />1.471561e-4 weeks <br />3.38645e-5 months <br /> on site by two regional based inspectors.

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-2-Results:

One item of noncompliance was identified regarding failure to follow procedures in two areas related to valve positioning and posi-tive control (four examples) (Infraction, Paragraph 3.c.).

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DETAILS 1.

Persons Contacted E. Baur, Performance Engineer, Electrical J. Carroll, Performance Engineer, Operations

  • R. Denton, Nuclear Plant Engineer, Operations C. Dunkerly, Shift Supervisor B. Hiestand, Reactor Operator J. Hill, Shift Supervisor T. Jones, Control Room Operator M. Roberson, Assistant General Foreman, Maintenance W. Rummel, Control Room Operator L. Russell, Chief Engineer A. Schumaker, Control Room Operator L. Strayer, Senior Control Room Operator L. White, Shift Supervisor S. Whitely, Reactor Operator The inspector also interviewed other licensee employees, including members of the administrative, technical and operations staff.
  • Denotes those present at ex interview.

2.

Purpose This inspection was conducted to verify that the licensee has taken the actions required by IE Bulletins 79-06 and 79-06B relating to a review of their facilities and operations, and that the facilities' operating staff is aware of procedural changes resulting from actions required in the bulletins.

3.

Inspection of Engineered Safety Features (ESF1 a.

General An on-site inspection of Engineered Safety Features was con-ducted which encompassed the following systems and components:

(1) Safety Injection System:

(a) safety injection tanks; (b) high pressure safety injection pumps; and (c) low pressure safety injection pumps.

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(2)

Containment Cooling Systems:

(a) containment spray; (b) containment air recirculation and cooling system; (c) containment penetration room ventilation system; and, (d)

containment iodine removal.

(3) Hydrogen Control Systems.

(4) Essential Support Systems:

(a) control systems; (b) normal and emergency power systems; (c)

component cooling system; (d)

service water system; and (e)

salt water system.

b.

Review of Valve / Breaker / Switch Alignment Procedures, Checkoff Lists and Piping and Instrument Diagrams (P&ID's Unit 2 (1) The inspector performed a comparison of the valve /

breaker / switch alignment procedures and checkoff lists (COL) for the following ESF systems against current P&ID's and single-line diagrams to verify the adeoi v

of alignment procedures.

The following items were reviewed:

P&ID 60-248-E, Containment, Turbine, Control Room;

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Penetration Room Ventilation Systems, Rev. 11, 3/15/71 (SH-1 and SH-2);

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P&ID 60-236-E, Containment Charcoal Filter Spray System, Rev. 3, 9/25/72; P&IO 62-731-E, Rev. 2, Safety Inspection and

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Containment. Spray System;

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OI-3 Safety Injection, Shutdown Cooling and Contain-

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ment Spray, Rev. 15, 10/25/78; OP-6 Pre-Startup Checkoff, Rev. 10, 10/25/78;

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STP 0-62-2 Monthly Valve Position Verification,

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Rev. 3, 3/15/78; P&ID 62-711-E, Rev. 3, Containment Charcoal Filter

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Water Spray System; P&ID 62-730-E, Rev. 2, Chemical and Volume Control

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System; OI-2A CVCS Volume Control, Rev. 13, 11/25/78;

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OI-29 Salt Water System, Rev. 4, 11/1/78;

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P&ID 62-233-E, Circulating Salt Water Cooling

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System, Rev. 6; 0I-15 Service Water System, Rev. 7, 4/26/78;

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P&ID 60-727-E, Rev. 1, Diesel Generator Cooling

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Water, Starting Air, Fuel and Lube Oil Systems; P&ID 62-706-E, Rev. O, Service Water Cooling

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Systerr-Auxiliary Building and Containment (Sheet 1);

P&ID 60-706-E, Rev. O, Service Water Cooling System-

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Auxiliary Building and Containment, Rev. 1, (Sheet 2);

OI-16 Component Cooling System, Rev. 7, 4/26/78;

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P&ID 62-710-E, Rev. 2, Component Cooling System;

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01-32 Auxiliary Feedwater, Rev. 10, 10/25/78;

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P&ID 62-702-E, Rev. 1, Condensate and Feedwater

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System; and P&ID 60-242-E, Rev. 9, Demineralized Water and

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Condensate Storage Systems.

(2) Electrical Breaker Alignment for Off-site and On-site Power - The breaker alignments were reviewed with a con-trol room operator, comparing a single line diagram to i<

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actual breaker positions using control room mimic busses.

In addition, the following detailed alignment procedures were reviewed by the inspector to assure that electrical power requirements were satisfied.01-27C, 4 kV System;-- 01-27D, 480 V System;-- 01-27B, 13.8 kV System;

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01-28, Operation of 500 kV Switchyard; and 1E-1 Electrical Main Single Line Diagram, Rev. 4,

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1/21/70.

c.

Verification of Valve / Breaker / Switch Alignment in ESF Systems byDirectObservationand[heckoffListCompletion Unit 2 The inspectors, accompanied by licensee representatives, verified ESF system valve / breaker / switch alignment by con-ducting the applicable system checkoff listed in Paragraph b.

above.

The above verifications confinned proper valve positioning and control except as indicated belo.v:

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IE Bulletin No. 79-068, item No. 7, required licensees of pressurized water power reactors to review all safet)

related valve positions, positioning requirements and positive controls to assure that valves remain positioned (open or closed) to allow the proper operation of engineered safety features.

OP-6, Attachment 7, Valve Lineup Checkoff, requires such valves to be locked in their designated position.

In response to the bulletin, the licensee accomplished a valve checkoff (Attachment 7 to OP-6) on April 16, 1979 to verify that all valves in Unit 2 were in their correct position and properly loc.cd.

Twenty-nine (29) valves which could not be verified due to inaccessibility during plant operation were excepted.

Unit i valves were not verified as the unit was shut down for refuel-ing and numerous valves would not be in their normal operating position as required by OP-6.

On May 9 and 10, 1979, an independent verification of the OP-6 valve

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lineup in Unit 2 was accomplished by an NRC inspector and the following deficiencies were noted:

Note: An (*) by valve indicates a deficiency which was corrected on-the-spot in the presence of the NRC inspector.

-- Valve 2-SI-455* required to be locked shut by the valve lineup sheet was found to be locked open.

-- Valve 2-CC-266 required to be locked open by the valve lineup sheet was found to be locked in an inter-mediate (throttled) position.

-- The following valves, required to be locked in pasi-tion by the valve lineup sheet, were found to be in their correct positicns but were not locked cr were improperly locked, i.e., the locking device was not pretent, was broken, or installed in such a manner that it would not preclude movement of the valve or that the locking device could be removed or rendered nonfunctional without disengaging its hasp:

2-CC-113 2-CVC-176*

2-CC-114 2-CVC-178*

2-CC-121 2-SI-329 2-CVC-172*

2-SI-453 2-SRW-127*

2-CC-243*

2-SRW-157*

2-CC-261*

2-CC-156*

2-SI-343 2-CC-162*

2-SW-198

-- 2-CVC-285 was verified to be in its proper position during the valve checkoff accomplished on April 16, 1979 as evidenced by the valve line-up check sheet.

This valve is in Containment and was not accessible for observation at the time of the valve lineup due to plant operations.

The operator stated he did not observe the valve and the annotation on the valve lineup sheet must have been an error.

The deviations from the required position on the valve lineup sheets were neither annotated on the lineup sheet nor on the Locked Valve Deviation Sheet as required by the CCOM.

The previous valve lineup verification was performed on April 16, 1979, as an action required in response to the bulletin and no evidence was found to indicate that the valves had been repositioned in the intervening interval.

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In the licensee's reply to IE Bulletin No. 79-068, the licensee stated that red and green color coded tags are attached to valves to indicate their designated position.

During his tour, the inspector noted that these tags were missing from many valves.

During the exit interview, the licensee representative acknowledged the deficiencies as identified above and stated the followina corrective actions had been taken or were to be taken:

-- All valve position and locking device deficiencies noted which were not corrected on the spot had been corrected;

-- The position of locked valves will be checkad-monthly by a new surveillance procedure which would be issued.

The sur-veillance procedure will check the following:

a.

Valve is in correct position; b.

Locking device is properly installed; c.

Color coded red / green valve position tags are installed.

-- Color coded red / green valve position tags and valve

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identification to be installed with a loc'< wire as present chains for securing these tags have been subject to pilferage.

-- OP-6, Attachment 7, will be changed to reflect that the correct position for 2-CC-266 is the locked throttle position.

These examples of failure to follow procedures for valve position-ing and positive control when taken collectively constitute an infraction level item of noncompliance (79-06-01).

4.

System Operability Following Maintenance and Test Activities The inspector reviewed for adequacy the administrative controls imposed by the licensee to assure proper return to service of ESF components following maintenance and test activities.

The follow-ing administrative controls were reviewed:

CCI 1128, Safety and Safety Tagging, 7/17/78;

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CCI, Maintenance Requests, 12/16/77; CCI 201A, Calvert Cliffs Nuclear Power Plant Maintenance

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Procedures, 11/21/77; and

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CCI 104C, Surveillance Test Program, 2/12/79.

The inspector verified by review of the above administrative con-trols, and review of applicable test and maintenance procedures, that when equipment is returned to service after maintenance, the Senior Control Room Operator (SCRO) verifies restoration of the equipment to service.

This action is formally acknowledged on the Maintenance Request.

Post maintenance testing is also noted on the Maintenance Request.

Upon completion of surveillance testing, the Shift Supervisor (SS)

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verifies that the test is completed and that the necessary steps are performed to return the system to normal.

The inspector had no further questions in this area.

5.

Review of Plant Surveillance Test and Maintenance Procedures The inspector reviewed the following current, approved surveil-lance test and maintenance procedures to verify that when the surveillance and maintenance is completed, the applicable compo-nent or system will have been returned to an operable condition.

In addition, the inspector reviewed the following procedures to verify that acceptance criteria were satisfied for ESF and other areas regarding the latest surveillance conducted on these systems:

(Inspection effort was restricted to individual tests and did not encompass review of surveillance frequency.)

Units 1 and 2

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Gen. 4, Valve Maintenance Procedure, Rev. 2, 9/13/78; Gen. 6, Pump Maintenance Procedure, Rev. 1, 9/13/78;

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Surveillance Test Procedure, STP-0-90-2 " Breaker Lineup

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Verification, Rev. O, 7/26/78;

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STP 0-7-2 ESFAS Logic Tert, Rev. 6, 1/3/79 (Engineered Safety Features Actuation System Monthly);

STP 0-55-2 Containment / Integrity Verification, Rev. 5,

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4/27/77;

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STP 0-8-0 Diesel Generator Weekly Test, Rev. 5, 9/20/78;

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STP 58-2 H Recombiner 18-Month Test, Rev. O, 7/27/76;

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STP 0-2P-2 H Recombiner Semiannual Test, Rev. O, 7/27/76;

STP 0-70-2 Staggered Test of "A" Train Components, Rev. O,

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12/8/76 (Containment Cooling System and Penetration Room Exhaust System);

STP 0-71-2 Staggered Test of "B" Train Components, Rev. 1,

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5/26/77;

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STP 0-8-0 Diesel Generator Weekly Test, Rev. 5, 9/20/78;

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STP 0-65-2 Quarterly Valve Operability Verification -

Operations, Rev. 5, 1/11/79; STP 0-69-2 SG/S Logic Test, Rev. O, 11/18/76;

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STP 0-74-2 Engineered Safety Features Equipment Inservice

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Bearing Temperature Test, Rev. O, 4/6/77;

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STP 0-68-2 Refueling Cycle Valve Position Indicator Test, Rev. O, 9/2/76;

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STP 0-60-2 Containment Purge System Isolation Test, Rev. O, 7/27/76;

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STP 0-58-2 H Recombiner 18-Month Test, Rev. O, 7/27/76;

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SYP 0-56-2 ESFAS Equipment Response Time Test, Rev. O, 8/6/76; STP 0-35-2 Safety Injection Tank Outlet Valve Test, Rev. O,

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7/27/76;

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STP 0-4-2 Integrated Engineered Safety Features Test, Rev. O, 10/18/78; STP 0-90-2 Breaker Lineup Verification, Rev. O, 7/26/78;

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STP 0-73-2 Engineered Safety Features Equipment Performance Test, Rev. 4, 2/28/79;

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STP 0-67-2 Check Valve Operability Verification, Rev. 2, 11/10/77;

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STP 0-66-2 Quarterly Valve Operability Verification - Shut-down, Rev. 6, 11/15/78; STP 0-62-2 Monthly Valve Position Verification, Rev. 3,

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3/15/78;

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STP 0-64-2 Check of Safety Injection Tank Feeder Breakers, Rev. 1, 11/1/78;

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STP 0-5-2 AJXiliary Feed System, Rev. 7, 1/8/79; STP 0-1-2 MSIV Full Stroke Test, Rev. 1, 10/27/76;

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STP 0-7-2 ESFAS Logic Test, Rev. 6, 1/3/79;

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STP 0-65-1 Quarterly Valve Operability Verification -

Operating, Rev. 5, 10/11/78;

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STP 0 68-1 Refueling Cycle Valve Position Indicator Test, Rev. O, 2/17/77;

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S7> 0-28-1 H Recombiner Semiannual Test, Rev. O, 1/28/77; t

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STP 0-4-1 Integrated Engineered Safety Features Test, Rev. 3, 2/15/77;

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STP 0-8-0 Diesel Generator Weekly Test, Rev. 5, 9/20/78;

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STP 0-69-1 SGIS Logic Test, Rev. 1, 5/11/78;

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STP 0-90-1 Breaker Lineup Verification, Rev. O, 7/26/78; STP 0-4-1 Integrated Engineered Safety Features Test, Rev. 3,

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2/15/77;

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STP 0-74-1 Engineered Safety Features Equipment Bearing Temperature Test, Rev. 1, 3/8/79;

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STP 0-73-1 Engineered Safety Features Equipment Performance Test, Rev. 7, 3/8/79; STP 0-1-1 MSIV Full Stroke Test, Rev. O, 4/4/77;

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STP 0-5-1 Auxiliary Feedwater System, Rev. 2, 1/11/79;

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STP 0-7-1 ESFAS Logic Test, Rev. 5, 12/27/78;

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STP 0-35-1 Safety Injection Outlet Isolation Valve Test, Rev. O, 1/21/77;

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STP 0-55-1 Containment Integrity Verification, Rev. 2.

4/25/77;

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STP 0-56-1 ESFAS Equipment Response Time Test, Rev. O, 2/2/77; i

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STP 0-58-1 H Recombiner 18-Month Test, Rev. O, 1/28/77;

STP 0-60-1 Containment Purge System Isolation Tesc, Rev. O,

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2/9/77;

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STP 0-62-1 Monthly Valve Position Verification, Rev.1, 11/23/77; STP 0-64-1 Check of Sr Tank Feeder Breakers, Rev. 1, 11/15/78;

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STP 0-66-1 Quarterly Valve Operability Verification

, Shut-down, Rev. 3, 2/15/78;

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STP 0-67-1 Check Valve Operability Versfication, Rev. 3, 5/17/78; STP 0-70-1 Staggered Test of "A" Train Components, Rev. O,

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2/9/77;

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STP 0-71-1 Staggered Test of "B" Train Components, Rev. 2, 9/21/77; STP M-220-2 ESFAS Functional Test, Rev. 3, 6/30/77;

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STP M-520-2 ESFAS Calibration, Rev. O, 8/4/70,

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STP M-521-2 ESFAS Response Time Test, Rev. 1, 12/1/76;

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STP M-522-2 UV Relay (ESFAS) Calibration, Rev. 1, 11/12/77;

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STP M-544-2 Penetration Room Exhaust Filter Test (HEPA),

Rev. 1, 5/27/77;

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STP M-545-2 Pentration Room Exhaust Filter Test (Charcoal),

Rev. O, 9/9/76;

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STP M-546-2 ECCS Pump Room Exhaust Filter Test (HEPA), Rev. 1, 5/27/77;

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STP M-547-2 ECC Pump Room Exhaust Filter Test (Charcoal),

Rev. 1, 9/9/76;

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STP M-548-? Containment Iodine Removal System Filter Test (HEPA), Rev. O, 9/2/76;

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STP M-549-2 Containment Iodine Removal Filter Test (Charcoal),

Rev. 1, 5/5/77; i'

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STP M-561-2 Radiation Monitoring Calibration, Rev. 3, 7/26/78;

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STP M-580-2 H Recombiner Control Calibration, Rev. 1,

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1/24/78; Recombiner Inspection and Resistance Check, STP M-581-2 H,6;

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Rev. 1, 8/19/7 STP M-220-1 ESFAS Functional Check, Rev. 1, 8/3/77;

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STP M-520-1 ESFAS Calibration, Rev. 1, 1/24/78;

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STP M-521-1 ESFAS Response Time Test, Rev. 1, 9/13/78;

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STP M-522-1 UV Relay (ESFAS) Calibration, Rev. 1, 11/12/77;

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STP M-544-1 Penetration Room Exhaust Filter Test (HEPA),

Rev. 1, 5/27/77;

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STP M-545-1 Penetration Room Exhaust Filter Test (Charcoal),

Rev. O, 1/3/77;

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STP M-546-1 ECCS Pump Room Exhaust Filter Test (HEPA),

Rev. 1, 5/27/77; STP M-547-1 ECCS Pum; Room Exhaust Filter lest (Charcoal),

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Rev. O, 1/3/77;

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sip M-548-1 Containment Iodine Removal Filter Test (HEPA),

Rev. 1, 1/3/77;

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STP M-549-1 Containmrst Iodine Removal Filter Test (Charcoal),

Rev. O, 1/3/77;

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STP 561-1 Radiation Monitorirl Calibration, Rev. 3, 7/26/78;

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STP 581-1 H,/77; Recombiner Inspection and Resistance Check, Rev. O, 1/19 STP 580-1 H Recombiner Control Calibration, Rev. 2, 1/24/78;

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STP M-620-1 Spray Nozzle Test, Rev. O, 4/27/79;

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STP M-551 Diesel Generator Trip Bypass on SIAS, Rev. O, 7/27/76;

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STP M-540-0 Control Rcom Post-LOCI Filter Test (HEPA),

Rev. O, 9/2/76;

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STP M-541-0 Control Room Post-LOCI Filter Test (Charcoal),

Rev. O, 9/9/76; STP M-542-0 Spent Fuel Storage Filter Test (HEPA), Rev. 2,

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5/27/77; and STP M-543-0 Spent Fuel Storage filter Test (Charcoal),

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Rev. O, 9/4/76.

The inspector had no further questions in this area.

6.

ESF System Operability Following an Extended Outage The inspector reviewed for adequacy the administrative controls imposed by the licensee to assure ESF systems are returned to an operable status at the conclusion of extended outages.

Following an extended outage, General Procedure OP-6 " Pre-Startup Checkoff" is performed prior to reactor startup.

The inspector reviewed OP-6, Revision 10, dated 10/25/78, to ensure it addressed all the ESF systems and returned them to an operable status.

The inspector had no further questions in this area.

7.

Independent Verification of Valve / Breaker / Switch Alignments The licensee does not perform independent verification of valve /'

breaker / switch alignments following extended outages or after maintenance / test activities.

Operators perform the above align-ments and they are then reviewed by the Senior Control Room Operator (SCRO).

8.

Auxiliary Feed Water System a.

The inspector verified by direct observation that all valves in the auxiliary feed water system are in the proper position and that all valves in the system identified by the licensee as requiring locking or similar positive position control are actually locked or controlled.

b.

The inspector verified that upon a receipt of a plant trip the Reactor Operator in the control room has been instructed by the Nuclear Plant Engineer, Operations via a " Standing Instruction" to direct immediately his sole attention to the maintenance and/or restoration of feed water flow via the main

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feed pumps or auxiliary feed pumps as required by the situation.

The inspector had no further questions in this area.

9.

Onsite Assessment of Operating Procedures a.

The inspector reviewed plant procedures and verified that applicable procedures have been revised as necessary to incorporate specific instructions in the following areas:

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The plant emergency procedure for a loss of coolant accident has been revised and expanded to emphasize the recognition and prevention of void formation in the RCS and the enhancement of core cooling subsequent to void formation should it occur.

Such actions are primarily based on the operation of the High Pressure Safety Injec-tion (HPSI) systems, the Reactor Coolant Pumps and natural circulation flow.

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The plant emergency procedures regarding the initiation of ECCS have been t-viewed and the emergency pro.edure for a loss of coolant accioent has been revised based on the specific instructions required by IEB-79-06B.

The review and a?terations to the procedures have provided for the folloving specific considerations:

(1) Procedttres which require the override of Engineered Safety Features (ESF) signals have been reviewed; such overrides are deemed to be appropriate and not to cause any adverse effects on needed safety features to support core cooling.

For example, once containment pressure decays below the CSAS/CIS setpoint, it is desirable to reset and reestablish coolirg flow to the RCP's, as well as inhibit Contai.1 ment Spray to prevent unnecessary damage to the RCD's (Containment coolers are fully redundant to the spray system).

(2) The emergency procedure for a loss of reactor coolant has been revised to include the specific instructions required by the subject bulletin regarding the conditions required before the HPSI system can be inhibited following automatic initia-tion of ECCS.

(3) The emergency procedure for a loss of reactor coolant has been revised to require the continued

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if operation of one RCP in each loop (if power is available) as long as forced flow is being provided by the pumps, as indicated by pump amps, whenever the core outlet temperature is less that 20 F subcooled.

All RCP's may be stopped if the core outlet temperature is more than 20 F subcooled.

(4) Appropriate cautions have been added to the loss of reactor coolant procedure regarding reliance on the pressurizer level instruments.

Specifically, these instruments should not be the sole source of informa-tion by which the HPSI system is stopped; the criteria discussed above must be met before the HPSI system is inhibited.

(5) During normal operations, pressurizer temperature is maintained at least 50 F above the reactor coolant system temperature by proper operation of the Chemical Volume Control System (CVCS), pres-surizer heaters and,nressurizer spray.

These systems are normally operated in the automatic mode and have associated control board alarms to provide annunciation of off-normal conditions.

Procedures governing the routine operation of pressurizer pressure control, CVCS, and degas were reviewed and found to be adequate.

Additionally, the procedures governing non routine plant evolutions, such as establishing and recovering from solid water condi-tions, were reviewed and deemed to provide adequate assurance of maintaining subcooled RCS conditions.

(6) Partial actuation (one train) of safety injection to assist in level control of the pressurizer during routine operation is not applicable to this facility because the maximum discharge head of the high pressure safety injection pumps is 1300 psig and, therefore, it would not be able to inject at nominal system pressure of 2250 PSIA.

(7) E0P-5, " Emergency Procedure for Loss of Reactor Coolant" was revised to include specific indications to be used in identifying an open PORV and to direct that the appropriate block valve be closed should one of the PORV's remain stuck open.

(8) E0P-3, " Loss of Main Feed Water" contains instruc-tions on feeding a dry steam generator.

In addi-tion, CCI-301, " Recording of Plant Transients /

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Operational Cycles,"Section II.2., discusses plant parameters and design restrictions for feeding a hot, dry steam generator.

(9) The licensee's practice and policy described in CCI-1128, " Safety and Safety Tagging," is to curl tags when placed so that the potential for obscur-ing status indicators, such as valves, switch posi-tions, etc., will not occur.

The inspector noted during his tours of the faci'.,,y that this practice is not being rigidly adhered to in that many tags were observed to be obscuring switches, valve position indication, meters, and alarms.

The inspector had no further questions concerning this matter at this time.

10.

Onsite Re'/iew of Operator Training a.

A detailed briefing regarding the Three Mile Island Unit 2 incident was given on site by representatives from NRC on April 19,1973.

Two sessions were held which were attended by licensed operators and station management.

A third ses-sion was conducted on off-shift hours by a Region I inspector for those individuals who could not attend either of the other two briefings.

b.

The licensee conducted training sessions on April 4, 1979 and April 11, 1979.

The following areas were discussed:

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Differences in design between Calvert Cliffs and Three Mile Island;

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Evente during the TMI incident; Actions to be taken in response to IEB-79-06B;

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Emergency Operating Procedures (EOP's) and safety analysis for the particular LOCA incident resulting from a stuck open PORV;

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Indications at Calvert Cliffs for the detection of an open PORV and subsequent actions required; and Review of revised E0P's issued as a result of actions

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required by IEB-79-06B.

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c.

The inspector interviewed nine licensed operators covering all three shifts.

Items discussed were as follows:

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Recent revisions to facility procedures listed in Para-graph 9 above relative to their knowledge and under-standing of the changes; Ability to recognize applicable plant parameters to

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determine if natural circulation is in effect; Importirce of maintaining forced circulation flow of

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reactor coolant (RCP's) as long as possible; and Methods for determining subcooling of reactor coolant

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system coincident with operation of high pressure safety inspection pumps.

The inspector had no further questions at this time.

11.

Prompt Reportino of Significant Events In order to provide earlier notification of the reactor not being in a controlled or expected condition of operation, the licensee has adopted a policy of reporting within one hour any plant condi-tion which requires the automatic or manual initiation of the ECCS system.

The inspector verified that a dedicated direct line-type communica-tion, independent of the licensee's normal system, has been installed between the site and NRC.

12.

Exit Interview The inspector met with a licensee representr'ive (denoted in Paragraph 1) at the conclusion of the inspection on May 11, 1979.

The inspector summarized the purpose, scope and findings of the inspection as detailed in this report.

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