IR 05000317/1980016
| ML19350C079 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/12/1981 |
| From: | Architzel R, Bland J, Callahan C, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19350C073 | List: |
| References | |
| 50-317-80-16, 50-318-80-15, NUDOCS 8103300367 | |
| Download: ML19350C079 (24) | |
Text
50317-800815 50317-800718 50317-801001 50317-801025
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50317-800903 50317-800613 50317-801008 50317-801021 50317-800830 50317-800430 50317-801014 50317-801019
- 0911 50318-801026 U.S. NUCLEAR REGULATORY COMMISSION N
ION AND ENFORCEMET 503 -
50317-800801 Region I 50-317/80-16 Report No. 50-318/80-15 50-317 Docket No. En U R DPR-53 License No. OpR 69 Priority
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Category C
Licensee:
Baltimore Gas and Electric Comoany P. O. Box 1475 Bal timore, Maryland' 21203 Facility Na..ie:
Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection at: Lusby, Maryland Inspection conducted:
October 1 - 31, 1980
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f Pd Inspectors:
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R. E. Architzel Senior Resident Reactor Inspector ddtd si ned N. $ a W
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C. J. Cal' ahan, Resident Rfeactor Inspector date/ signed BM fn nMeo J. S. Bland, Radiation Specialist date signed Itz./ r/
Approved.by:
8.6 M +4c, b
E. C. McCabe, Jr., Chief, Reactor Projects date signed Section No. 2, RO&NS Branch
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, Inspection Sumary:
Inspection on October 1-31, 1980 (Combined Report Nos. 50-317/80-16 and 50-318/80-15)
Areas Inspected: -Routine, onsite regular and backshift inspection by the resident office staff (95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br />, Unit 1; 80.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, Unit 2).
Areas inspected included the control room and the accessible portions of the auxiliary, turbine, service, and intake buildings; radiation protection; physical security; fire protection; plant operating records; reporting to the NRC; radioactive waste systems; TMI Action Plan Category "A" Requirements; and open items.
Noncompliances: Five(Not operating all radioactive waste equipment when releases exceeded 1.25 curies,- paragraph 6; Failure to follow emergency plan implementing procedures (Unit 1), paragraph 4; Failure to adhere to TS requirements for promo-tion of personnel, paragraph.2; and failure to notify the NRC within one hour of a Unit 2 trip, paragraph 4; Failure to maka 10 CFR 50.59 review of change in facility operations as described in'FSAR, paragrapn 6.)
Region I Form 12 (Rev. April;77)
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DETAILS 1.
Persons Contacted The following technical and supervisory level personnel were contacted:
G. E. Brobst, General Supervisor, Chemistry (Acting)
D. E. Buffington, Fire Protection Inspector J. T. Carroll, General Supervisor, Operations J. T. Carlson, Foreman, Radiation Safety J. G. Denton, General Supervisor, Training / Technical Services C. L. Dunkerly, Shift Supervisor W. S. Gibson, General Supervisor, Electrical & Controls J. E. Gilbert, Shift Supervisor D. E. Huseby, Engineering Technician J. R. Hill, Shift Supervisor L. S. Hinkle, Supervisor, Instrument Maintenance C. Key, Engineer, EED J. F. Lohr, Shift Supervisor D. W. Latham, Principal Engineer, Plant Engineering Nuclear R. O. Mathews, Assistant General Supervisor, Nuclear Security J. A. Mihalcik, Senior Engineer, Fuel Management M. J. Miernicki, Senior Engineer, Plant Engineering, Nuclear N. L. Millis, General Supervisor, Radiation Safety K. J. Nietmann, Engineer,-Modifications E. T. Reimer, Plant Health Physicist J. E. Rivera, Shift Supervisor P. G. Rizzo, Assistant General Foreman, Maintenance L. B. Russell,_ Plant Superintendent J. R. Speciale, Foreman, Radiation Safety T. L. Sydnor, General Supervisor, Operations QA K. G. Tietjen, Technical Specialist R. L. Wenderlich, Engineer, Operations (
M. J. Warren, Engineering Technician D. Zyriek, Shift Supervisor Other licensee employees were also contacted.
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2.
Licensee Action on Previous Inspection Findings a.
Waste Treatment Items (Closed) Unresolved Item (317/79-24-01; 318/79-23-01) Update
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Water Treatment Plant.
(Closed) Noncompliance (317/79-24-02; 318/79-23-02) Uncontrolled
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Discharge of Caustic Solution.
(Closed) Unresolved Item (317/79-24-04; 318/79-23-04) Revise
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Water Treatment Procedures.
The inspector reviewed the licensee's corrective and preventive mea-sures addressing the items addressed in Combined Inspection Report 317/79-24 and 318/79-23 and a subsequent management meeting. The items observed included the following:
Installation of curbing for No.12 Waste Neutralizing Tank (WNT)
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Installation of a WNT High Level Common Alarm on Control Room
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Panel 1C01 Permanent installation of No. 12 WNT on a foundation
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Installation of lined carbon steel piping in the supply lines to
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- 12 WNT Installation of a liner (epoxy type) on No. 12 WNT
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Completion of an evaluation of tank mixing adequacy
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l Revisions to OI 23D, Operation of the Waste Neutralizing System,
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l Revision 4, dated July 11, 1980 to include
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A waste Usage Permit (Attachment 2) requiring hourly l
logging of tank levels by the CR0 and approval of j
permit by the SCR0 l
ii) A valve checklist required to be used by outside operator (050)
l fii)Section III requires sampling of Service Building sumps l
prior to direct discharge to the yard interceptor
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Revisions to 0I 238, Demineralized Water System, (Revision 8
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dated July 11, 1980) and OI 11C, Condensate Demineralizer System l
(Revision 9 dated July 15, 1980) were reviewed to verify procedural
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changes made subsequent to water treatment plant modifications.
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Completion of operator training to support the revised procedures
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and permit system Repair of the plant page in the vicinity of the WNT's.
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The licensee's corrective actions in this area have apparently been effective in that additional unmonitored releases of the WNT's has not occurred.
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b.
Anchor Bolt Items (Closed) Unresolved Item (317/79-09-03) Review of the anchor
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bolt torque versus tension data.
During the June 18-21, 1979, inspection, the licensee was performing tests to establish a site specific torque versus bolt tension relationship for concrete expansion anchor bolts used for pipe supports.
This data is the basis for the anchor bolt preload values used to satisfy IE Bulletin 79-02.
The inspector reviewed the final report titled,
" Anchor Bolt Tension Testing Data," LETCO Project No. W-9-2444, and compared selected data from the report with the specified values in Civil Standard CS-5.
(Closed) Unresolved Item (317/79-09-01) Inconsistency in anchor
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bolt test methods in Civil Standard, CS-5.
The inspector re-viewed Civil Standard, CS-5, Revision 1, and verified that clarify-ing statements have been added to paragraph 2.3.2. describing when the " bridging" technique is to be used.
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c.
Other Items
(Closed) Unresolved Item (317/78-25-11 and 318/78-19-11) Visual
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Inspection Procedure for Snubbers.
The licensee stated that physical measurements of the extension of snubbers would be l
made in accordance with the 10 year ISI program per IWB-2500,
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examination category B-K-2.
In addition the licensee revised i
procedures STP M-13-1/2 (Revision 2/ Revision 2), Inaccessible I
Snubber Inspections, and STP M-12-1/2 (Revision 3/ Revision 2),
Accessible Snubber Inspections to add a new requirement to verify the snubber is not obviously frozen or the shaft position at the mechanical stop.
(0 pen) Unresolved Item (317/80-08-03; 318/80-08-03) Duties and
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Responsibilities of the Reactor Operator (RO).
The inspector l
reviewed this item and determined that the Shift Technical Ad-visors (STA) and Shift Supervisors Assistants (SSA) duties and responsibilities were not specified in applicable Quality Assurance Procedure (QAP) 25, Revision 8, Plant Operations.
The licensee has submitted changes which include these requirements.
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(Closed) Unresolved Item (318/80-10-01) Specify Prior Verifica-
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tion of Redundant Equipment Operability Prior to Removal from Service.
The inspector reviewed GSO Standing Instruction 80-12 which has been issued to address the requirement to verify redundant equipment operability and note this check in the CR0 Log book.
(Closed) Unresolved Item (317/79-17-02; 318/79-14-02) Mainten-
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ance of I&C and Mechanical Maintenance Training Records Deficient, Identified in Quality Assurance Audit Number 20-23-79.
The inspector reviewed the licensee's corrective action regarding the establishment of formal training programs for I&C and Mechanical Maintenance personnel.
One aspect of the training remains to be implemented for Mechanical Maintenance documentation of on-the-job training by supervisors.
This item is being tracked by the QA Auditor and is scheduled to be completed following the Unit 2 Refueling Outage in January, 1981.
During review of this item the inspector noted that Audit Finding Number 1 had not been resolved.
This item concerned a member of the facility staff (a PMD Modification Group Foreman) not meeting the requirements of ANSI N18.1, 1971 (High School Diploma).
The paperwork associated with this audit finding indicated that the licensee was internally pursuing an exception to the ANSI 18.1 requirement by revising the commitment to the Standard in the BG&E Quality Assurance Program.
But, the facility license requires adherence to the Technical Specifications (TS). The inspector noted that TS 6.3 requires the facility staff to meet the requirements of ANSI N18.1-1971.
The licensee's action to date has been inappro-priate, in that failure to have facility staff qualified in accordance with ANSI 18.1-1971 represents an uncorrected item of l
noncompliance with the facility license since about July 1979, I
with no action to modify or conform with the TS accomplished, even though the Quality Assurance audit identification of this ites was issued by report dated September 21, 1979.
This unresolved item is administrative 1y closed and reclassified as an item of noncompliance (317/80-16-01; 318/80-15-01).
(Closed) Unresolved Item (317/80-08-01, 318/80-08-01) Revise
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SEPIP's to Include Verification of Intake Structure Integrity for PMH.
The licensee revised the Emergency Response Plan Implementing Procedure Number 4.12 (Revision 0-Draft), Natural Events, to include a check of the Intake Structure water tight integrity.
(Closed)
Inspection Follow-up Item (317/79-22-01 and 318/79-21-
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l 01) Revision to 0I-17A For De-watering Plan.
The inspector veri-fied that procedure OI-17A had been revised to include the steps being employed for de-watering of the radioactive spent resins prior to shipment for low-level waste burial.
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(Close.1) Deficiency (317/79-08-04 and 318/79-07-04) Failure to
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Post Radioactive Material.
The inspector verified that the licensee had posted those areas previously identified as not being properly posted in accordance with the requirements of 10 CFR 20.203.
The inspector also questioned the licensee about the procedural change that was instituted to aid in preventing recur-rence.
Procedure RCP 3-401 was revised to more clearly define when an area becomes a Radioactive Material Area requiring posting in accordance with 10 CFR 20.203.
No other areas were identified as not being properly posted.
(Closed) Unresolved Item (317/80-14-01 and 318/80-13-01) Main
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Vent Flow Rate Recorder.
The inspector reviewed the licensee's FSAR and the Environmental Technical Specification 2.3.B.5.a.
Since the plant design never included a continuous flow rate recorder, the licensee's method of measuring and recording the main vent flow (twice per shift readings from a flow manometer)
meets the Technical Specificat.fon requirements that the flow rate be measured continuously and recorded.
The licensee is to install a main stack flow recorder by mid-1981, 3.
Review of Plant Operations a.
Plant Tour At various times the inspectors toured the facility, including the Control Ro m, Auxiliary Building (all levels, no High Radiation Areas),
Turbine Building, Outside Peripheral Area, Security Buildings, Health Physics Control Points, Diesel Generator Rooms, Service Building and Intake Structure.
Sampling checks of the following were made.
i Radiation controls established by the licensee, including posting
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of radiation areas, conditions of step-off pads and disposal of protective clothing.
Control Room manning, including observation of shift turnover and
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panel walkdowns.
Systems and equipment checks for the fluid leaks or abnormal
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piping vibration.
Seismic restraint and hydraulic snubber checks to verify adequate
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installation and fluid levels.
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I Plant housekeeping conditions, including general cleanliness and
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storage to preclude safety or fire hazard Control Room and local monitoring instrumentation for various
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components and parameters were observed, including reactor power level, CEA positions and safety-related valve position indication.
Whether proper access controls were established.
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During this inspection the licensee stated that Inservice Inspection detected Unit 1 RCP pump stud wastage on 27 of the 32 studs on 2 of the 4 Reactor Coolant Pumps.
Similar wastage had t?en noted at other plants and was the subject of IE Information Notice 80-27, Degradation of Reactor Coolant Pump Studs.
The inspectors will follow resolution of this concern.
(317/80-16-02).
b.
Review of Operating Loos, Records Logs and records were reviewed to identify significant changes and trends, to assure required entries were being made, to verify Operating Orders conform to the Technical Specifications, to verify proper identification of abnormal conditions, and to verify conformance to reporting requirements and Limiting Conditions for Operation. The following records were reviewed for the report period:
Shift Supervisor's Log
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Unit 1 Control Room Operator's Log
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Unit 2 Control Room Operator's Log
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Nuclear Plant Engineer - Operations Notes and Instructions
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Unit 1 and 2's Control Room Daily Operating Logs (sampling review)
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Service Building Operator's Log
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Review of previously completed shift turnover sheets indicated that Licensed Operators were not always listing Technical Specification action statements expiring on the next shift as required.
These items were being recorded on an additional information sheet.
The General Supervisor-Operations issued instructions regarding the requirement and emphasizing the importance of this entry.
Subsequent review showed that Licensed Operators were completing the item as intended.
Detail paragraph 4 describes an item of noncompliance associated with this area.
The inspector had no other questions on this item.
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4.
Review of Events Requiring One Hour Notification of the NRC i
The circumstances surrounding the following events requiring prompt (one hour) notification of the NRC via the dedicated telephone (ENS) were reviewed.
Unplanned radioactive material release on October 1,1980.
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l At 7:25 AM on October 1, 1980, Unit 1 main vent gaseous radiation monitor alarmed and indicated higher than normal for about 30 minutes.
l A plant emergency was initiated immediately and terminated at 8:55 AM.
The release was estimated to be 4.5% of the technical specification limit.
The inspector requested instrument checks, which verified operability of the alarmed radiation monitor and reviewed release calculation methods.
Selected individual operations which may have j
initiated the release were conducted without identifying the source.
j No unacceptable conditions were identified.
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l Unplanned radioactive material release on October 8, 1980.
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l Unit 1 main vent containment gaseous and control room radia-tion detectors alarmed and indicated higher than normal for about 5
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l minutes at 4:20 PM on October 8, 1980.
Samples taken at 4:55 PM
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indicated normal background.
The containment particulate detector l
recorded indication during this event was extremely erratic.
Subse-quent troubleshooting efforts determined that the detector leads were shorted at the detector due to moisture accumulation.
Various techniques were used to evaluate the potential for the detector's failure to initiate these alarms without conclusive resul+s.
The source of moisture accumulation in the detector housing has not been determined.
Calculations estimated the release to be 11% of the technical specifi-l cation instantaneous limit.
Review of this area showed that, following initial classification of this event as a Plant Emergency at 4:20 PM, the Shift Supervisor
" administratively" initiated the Plant Emergency.
Alarms were not
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sounded and the plant page was not used.
The Shift Supervisor stated
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this course was taken because he believed that an instrumentation j
problem existed and that no real release occurred. As a result of not I
announcing the condition as required, Radiation Protection personnel
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were not informed of the alarms for 35 minutes.
Airborne samples were considerably delayed, making the sample results of questionable value in substantiating the hypothesis of an instrumentation problem.
Licensee personnel could not conclusively state whether this event constituted an actual condition or an instrumentation problem. The inspector concluded that the ' event, even if actual, constituted no threat to the public health and safety, however the actions of the Shift Supervisor in not carrying out the appropriate portion of the l
SEPIPs resulted in'a less than totally effective response by plant personnel and was identified as an item of noncompliance. (317/80-16-03).
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Medical Emergency on October 14, 1980.
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A contractor employee was transported to Calvert Community Hospital about 11 AM on October 14, 1980 with symptoms of a heart attack.
Radioactivity was not involved.
No unacceptable conditions were identified.
Manual Trip on October 26, 1980.
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Unit 2 was manually tripped at 4:58 PM on October 26, 1980 because of low condenser vacuum due to failure of the motor coupling on Number 22 Condenser Air Removal Unit.
The failed coupling was repaired and the unit was taken critical at 11:09 PM.
Notification to the NRC was not made within the one hour required by 10 CFR 50.72.
The licensee did inform the NRC Operations Center about 7 AM on October 27 that a trip had occurred the previous day. This notification was made during the NRC's daily status report phone check.
Failure to make a timely notification in accordance with 10 CFR 50.72 is an item of noncompliance (318/80-15-02).
ESF Actuation on October 25, 1980.
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A Safety Injection Actuation signal was initiated in Mode 6 at 3:45 AM on October 25, 1980, when the inverter supplying one Engineered Safety Feature Actuation System (ESFAS) Cabinet was inadvertently deenergized with a second ESFAS cabinet deenergized for maintenance. Injection did not occur because system handswitches were placed in " pull to Lock."
No unacceptable conditions were identified.
Control Room Air Conditioning Failure on October 21, 1980.
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The Control Room Air Conditioning was out of service for approximately
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l eight minutes on October 21, 1980.
The running unit tripped while the,
l second unit was out of service for corrective maintenance.
The licensee had previously initiated an engineering design study and employed a I
l consultant to recommend corrective action for elimination of recurring l
Control Room Air Conditioning failures.
Corrective maintenance will I
be conducted during this outsge.
No temperature limits were approached.
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This item is also addressed in the LER Followup Section of this report.
This item will be followed up during routine inspection effort.
l Local Emergency on October 19, 1980.
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L A local emergency was declared at 4:45 PM on October 19, 1980 when i
airborne radioactivity levels increased in the Unit 1 containment. The L
cause of the increase was leaking PORV block valve packing.
Unit 1 I
was 2 days into a refugling outage with system pressure at 260 psig
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and temperature at 150 F.
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The valve was stroked earlier in the day for surveillance testing.
The leak was known to exist at normal operating pressure but the valve was not back seated after testing because it was assumed it would not leak at the lower pressure.
The leak was discovered at 3:30 PM and localized air sampling was immediately started to evaluate the radiological consequences.
No one was working in the pressurizer block house at the time of the leak.
A sample from the block house indicated airborne levels at 2.5 MPC for Iodine, 1.2 MPC for particulates, and 0.006 MPC gaseous.
Geneygl area air sampleg increased by a factor of about 10, from 2x10
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uC1/cc to 2x10 uCi/cc, gross beta / gamma. When the increases in activity were identified a Local Emergency was declared.
Contain-ment purge was secured and approximately 25 people were evacuated.
One individual in self-contained Breathing Apparatus reentered to back-seat the valve and stop the leak.
After the airborne activity levels decreased, the emergency was secured at 6:00 PM and access to containment was re-established.
The inspector reviewed the air sampling analysis and the radioactive effluent monitoring data.
No increase was detected in the effluent releases. No items of noncompliance were identified.
5.
In-olant Radiation Safety During auxiliary building tours, the inspector observed the in plant radiation safety (health physics) practices.
In particular, the inspector observed and evaluated:
1) worker adherence to radiation work permit requirements and general health physics procedures; 2) the posting of radiation areas, high radiation areas, and radioactive material areas; and, 3) radiation surveys for release of material from the radiologically controlled area to the clean area.
The licensee utilizes a " roving health physicist" to provide the general radiological safety coverage on a single buf1 ding elevation.
This approach calls for the health physics technician to be stationed on each elevation to be cognizant of work in the area and to make periodic surveys of the work area and radiation levels.
Continuous on-the-job HP coverage is provided only on operations identified as involving potentially significant radiological safety considerations.
The need for such coverage is evalu-ated at the time of issuance of a Radiation Work Permit (RWP).
A major fire protection modification in progress required erection of scaffolding throughout the auxiliary building for installation of overhead sprinklers. Work on the overheads is controlled by Special Work Permits (SWPs) which require the use of anticontamination clothing (coverall, shoe covers, and hood).
All workers observed in the overheads were appropriately dressed.
Worker egress from the radiologically controlled area was observed with regard for use of appropriate undressing techniques and personnel contamination surveys.
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Independent direct radiation measurements with a XETEX 305B survey meter were conducted at numerous locations throughout the auxiliary building and
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Unit I containment.
All areas evaluated were appropriately posted.
The inspector observed the radiation survey of materials prior to removal from the radiologically controlled area.
The release of all items to the clean area is covered by licensee procedure RCP 3-504.
That procedure establishes the radiological release limits for material to the clean area, i.e., establishes the levels of radioactive contamination that are detectable and must be treated as licensed material.
Tgelimitssetforthinthe procedure are:
1)lessthan1000dpm/100gm for loose surface beta / gamma contamination; 2) less tN n 100 dpm/100 cm loose surface alpha contamina-tion; and 3) less thaa
- .1 mR/hr near contact reading, open window fixed beta / gamma contamination.
The procedure states that an increase of 200 cpm above background on the HP 210 detector is represented by 1000 dpm beta / gamma under the area of the probe.
Swipes (removable contamination) greater than 200 cpm above background in a background area of less than 0.1 mR/hr must be further evaluated with a counter scaler.
The items being surveyed consisted of a mobile tool shed containing numerous hand tools.
Each item was surveyed and tagged for release individually by a health physics techni-cian.
Upon survey of the tool shed, detectable levels of contamination were identified.
The tool shed was appropriately tagged as radioactively contaminated and restricted from release to the clean area.
No items of noncompliance were identified.
6.
Radioactive Waste Systems a.
Liquid Radioactive Waste Treatment Systems The inspector discussed with the licensee the operation of the liquid radioactive waste treatment systems. Waste processing is divided into two separate systems:
the reactor coolant waste processing system (RCWPS) and the miscellaneous waste processing system (MWPS). The RCWPS receives liquids letdown from the Chemical and Volume Control i
System (CVCS) as necessary to maintain proper primary system inventory.
The primary system liquids are processed through a filter to remove
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I insoluble particles and a vacuum degassifier to remove hydrogen and
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fission product gases. The degassed liquids are then processed through ion exchangers to remove soluble impurities and pumped to the Reactor
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Coolant Waste Receiver Tank (RCWRT).
From the RCWRT the liquid is processed by a vacuum evaporator.
The distillate is sampled for discharge to the bay; the evaporator bottoms (concentrated boric acid)
are re-used for borating the RCS. This waste processing method elimin-ates the need for solidifying the evaporator bottoms.
The MWPS receives liquids from equipment drains, floor drains, labora-
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tory sinks, laundry, and decontamination facilities.
That waste is processed, as necessary, by filtration and ion exchange prior to
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discharge to the bay.
The miscellaneous waste evaporator installed in the original plant design has never been used, reportedly because the licensee does not have a method for processing the evaporator bottoms.
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The solid waste processing system installed in the facility has never been used, reportedly because of design deficiencies.
The miscellaneous waste evaporator is not maintained but is used for spare parts for the two RC waste evaporators.
The use of the miscellaneous waste evaporator is addressed in the licensee's FSAR and is further discussed in the licensee's Appendix I evaluation report dated October 1, 1976.
The licensee's evaluation to demonstrate that liquid radioactive effluents can be maintained to as low as reasonably achievable (ALARA) levels in accordance with the requirements of 10 CFR 50.34a and Appendix I to Part 50 cor.siders the use of the miscellaneous waste evaporator.
Environmental Technical Specification 2.3. A.5 requires the equipment installed in the liquid radioactive waste system be maintained and operated to process all liquids prior to discharge when releases will exceed 1.25 curies per unit during any calendar quarter, excluding tritium and dissolved gases.
During the last quarter of 1979 the licensee had liquid effluent releases of 4.54 curies, excluding tritium and dissolved gases.
This quantity exceeded the Technical Specification waste processing set point of 1.25 curies; however, the miscellaneous waste evaporator was not maintained and used to further reduce the effluent prior to discharge.
Failure to maintain and operate the miscellaneous waste evaporator for processing of liquids prior to discharge when releases exceed 1.25 curies per unit during the last calendar quarter in 1979 is an item of noncompliance (317/8v-16-04; 318/80-15-03).
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b.
Gaseous Radioactive Waste Treatment Systems The inspector questioned the licensee about potentially explosive mixtures in the waste gas system.
The licensee stated that the oxygen analyzer installed for evaluating the oxygen content at selected locations through the. waste gas system has not been in operation for several years.
The Calvert Cliffs FSAR, Section 9.6.2.5, " Gas Analyzing System,"
addresses the design and operation of the oxygen analyzer.
The oxygen analyzer, as designed, measures oxygen content at the following locations:
the three waste gas decay tanks, the waste gas surge tank, the two RC drain tanks, the two vacuum degassifier discharges, and the two RCWPS evaporator vacuum pump discharges. Since PWR waste gas is hydrogen rich, oxygen introduction can produce a dangerous mixture.
The oxygen analyzer can provide early indication of oxygen introduction problems.
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The licensee stated that, when Calvert Cliffs first became opera-tiuaal, waste gas system oxygen inleakage was identified as a problem.
Design modifications were made to eliminate that inleakage. The system was analyzed for oxygen for some period of time after the modification; no indication of any additional oxygen inleakage was detected.
However, for the past several years, the oxygen analyzer has not been operated, nor has the licensee routinely taken gas samples to provide warning of system operational problems.
10 CFR 50.34(b)(6)(iv) specifies that the FSAR is to include plans for conduct of normal operations.
The Calvert Cliffs FSAR, Section 9.6.2.5, describes the Gas Analyzing System and states that it is used to determine the hydrogen'and oxygen concentration of several samples from the reactor coolant and miscellaneous waste systems. 10 CFR 50.59 permits changes in the facility as described in tne FSAR if it is determined, by written safety evaluation, that no unreviewed safety question exists and if the changes made, with summaries of the safety evaluations, is included in an annual report to the NRC.
The non-utilization of the oxygen analyzer constitutes a change in the facility as described in the FSAR, with no safety evaluation made or a report of that change submitted.
This is an item of noncompliance (317/80-16-05; 318/80-15-04).
c.
Radioactive Material Shipment The inspector reviewed a shipment of radioactive material for compliance with the appropriate NRC and 00T regulations.
The shipment consisted
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of anti-contamination clothing packaged in 55 gallon drums for transport as an LSA, exclusive-use shipment to a vendor in New York for launder-ing.
The inspector reviewed the shipping papers for inclusion of appropriate entries, e.g., classification of material, activity of
'each package, labeling, and transport index.
Also, the radiation survey of the transport vehicle (trailer and cab) were observed.
The shipment was verified to be properly blocked and braced to prevent l
load shift under conditions normally incident to transportation.
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The licensee surveyed each package (55 gallon drum) for direct radiation and removable contamination prior to loading.
The drums were weighed and appropriately labeled.
For the laundry shipment examined, the packages bore the physical weight and the labeling, " Radioactive -
LSA."
No unacceptable conditions were identified.
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7.
Solid Waste Processing and Storage The inspector reviewed FSAR section 11.1.2.4, Solid Waste Processing System, and interviewed the Plant Health Physicist to obtain answers to specific questions requested by the NRC.
The following answers were obtained describ-ing the'Ifcensee's facilities / plans.
The licensee does not have a low level waste storage facility (Process-
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ing facility only).
The licensee's current equipment does not meet the January, 1981
--
burial criteria.
'
The licensee is contracting to obtain a quali.fied system.
--
The binder to be used is uncertain.
--
--
No low level waste is currently in storage.
The licensee is actively investigating the construction of a solid
--
waste storage room.
Completion is expected in early 1981.
The facility is planned to be a new, concrete building, outside the present protected area fence.
About 13,000 cubic feet of storage will be available (six
,
'
to twelve months waste).
The type of waste to be stored is dry waste and dewatered resins.
No unacceptable conditions were identified.
8.
Observation of Physical Security l
The resident inspector checked, during regular and off-shift hours, on whether selected aspects of security met regulatory requirements, physical security plans and approved procedures.
l a.
Physical Protection Security Organization
.
I Observations and personnel interviews indicated that a full time
--
l member of the security organization with authority to direct l
physical security actions was present, as required.
!
(
Manning of all three shifts on various days was observed to be as
--
!
required.
b.
Physical Barriers Selected barriers in the protected area (PA) and the vital areas (VA)
l
were observed and random monitoring of isolation zones was performed.
Observations of truck and car searches were made.
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Access Control Observations of the following items were made:
Identification, authorization and badging
--
Access control searches
--
Escorting
--
Communications
--
Compensatory measures when required.
--
No unacceptable conditions were identified.
9.
Inspection of TMI Task Action Plan Category "A" Requirements a.
References (1) NUREG 0578, TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations, July, 1979.
(2) NRC letter (Eisenhut) dated September 13, 1979, to All Operating Nuclear Power Plants, Follow-up Actions Resulting from the NRC Staff Reviews Regarding the Three Mile Island Unit 2 Accident.
(3) NRC letter (Denton) dated October 30, 1979, to All Operating Nuclear Power Plants, Discussion of Lessons Learned Short Term
Requirements.
l l
(4) NRC letter (Eisenhut) dated April 25, 1980, to All Power Reactor l
Licensees, Clarification of NRC Requirements for Emergency Response l
Facilities at Each Site.
(5) NRC letter (Eisenhut) dated May 7, 1980, to All Operating Reactor Licensees, Five Additional TMI-2 Related Requirements to Operating
,
l Reactors.
!
,
(6) NUREG-0660, NRC Action Plan Developed as a Result of the TMI-2 Accident.
,
(7) NRC letter (Eisenhut) dated September 5, 1980, to All Licensees of Operating Plants and Applicants for Operating Licenses ind Holders of Construction Permits, Preliminary Clarification of TMI Action Plan Requirements.
!
!
.
(8) BG&E letter (Lundvall) dated October 19, 1979, to the NRC (Eisenhut),
CCNPP Follow-up Actions Resulting from TMI-2 Incident.
(9) BG&E letter to the NRC dated November 9, 1979 (Lundvall to Reid),
-Follow-up Actions Resulting from TMI-2 Incident.
(10) BG&E letter to the NRC dated November 20, 1979 (Lundvall to Eisenhut), Follow-up Actions Resulting from TMI-2 Incident.
(11) BG&E letter to the NRC dated December 5, 1979 (Lundvall to Eisenhut), Follow-up Actions Resulting from TMI-2 Incident.
'
(12) BG&E letlar to the NRC dated December 14, 1980 (Lundvall to Eisenhut), Follow-up Actions Resulting from TMI-2 locident.
(13) BG&E letter to the NRC dated January 4, 1980 (Lundvall to Eisenhut),
Follow-up Actions Resulting from TMI-2 Incident.
(14) BG&E letter to the NRC dated January 25, 1980 (Lundvall to Reid), Automatic Initiation of Auxiliary Feedwater System.
(15) BG&E letter to the NRC dated February 1, 1980 (Lundvall to Eisenhut),
Follow-up Actions Resulting from TMI-2 Incident (Lessons Learned).
(16) BG&E letter to the NRC dated February 29, 1980 (Lundvall to Reid), Follow-up Actions Resulting from TMI-2 Incident (Lessons Learned).
(17) BG&E letter to the NRC dated March 12, 1980 (Lundvall to Reid),
.
Follow-up Actions Resulting from THI-2 Incident (Lessons Learned).
(18) BG&E letter to the NRC dated April 22, 1980 (Lundvall to Eisenhut),
Follow-up Actions Resulting from TMI-2 Incident (Lessons Learned Short Term).
(19) NRC letter dated April 7,1980 (Reid to Lundvall), forwarding the NRC Staff's "Calvert Cliffs Units 1 &2 Evaluation of Category "A" Lessons Learned Implementation."
b.
Using the commitments detailed in references 8 through 17 above, the inspectors confirmed the implementation of selected TMI Task Action Plan Category "A" requirements.
The referenced NRC documents were used as a guide in inspecting the licensee's implementation. Acceptance criteria for the verification was in conformanct to the licensee's commitments. The items reviewed are listed below.
The number designa-tion of each item is consistent with the identification used in NUREG-0578 (corresponding NUREG-0660 numbers are noted in parentheses).
.
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.
2.2.1.b (I.A.1.1) Shift Technical Advisor On Duty.
--
The licensee has implemented a program (described in reference 12) which uses the on-shift Senior Control Room Operator (SCRO)
to provide the accident assessment function and a standing committee of Plant Engineers (described in references 12 r,d 18), called the Operating Experience Assessment Committee, to review the operating experiences of other plants.
One additional SOL has been added to each shift to act as the Shift Supervisor's Assistant and to become the SCR0 for the unaffected unit in the event of an incident requiring a STA.
The inspector verified, through frequent observations and discussions and review of the OEAC meeting minutes, that the licensee's commitments were being implemented.
2.2.1.a (I. A.1.1. I.C.3) Shift Supervisor Responsibilities Specified.
--
The inspector interviewed licensed operators and shift supervisors regarding individual responsibilities during normal and accident conditions.
The current shift manning requirements and respon-sibilities are specified in the operations standing orders.
Re-view of Quality Assurance Procedure (QAP) No. 25, Revision 8, Plant Operations, resulted in the determination that the Shift Technical Advisor (STA), Shift Supervisor Assistant (SSA) and Reactor Operator (RO) duties, responsibilities and line of command functions relative to other plant management personnel were not specified in this document.
The licensee has submitted a change to QAP-25 which includes these requirements.
Training programs for shift supervisors currently include two weeks of supervisory skills and personnel management seminars.
A manage-ment directive concerning Shift Supervisor Responsibilities was issued by the Vice President-Supply on December 18, 1979. Revision of QAP-25 is an Unresolved Item (317/80-08-03; 318/80-08-03).
(I.C.2) Shift and Relief Turnover Procedures.
--
The inspector reviewed the licensee commitments stated in references 10 and 13, applicable operations standing orders and Quality Assurance Procedure (QAP-25).
Numerous Control Room shift turnovers were observed.
No failure to meet licensee commitments was identified.
2.2.2.a (I.C.4) Control Room Access
--
The inspector reviewed QAP-25, Plant Operations, Revision 8 dated June 26, 1980 and noted that the Shift Supervisor's responsibility
to control access is clearly stated.
In addition, GSO Standing Instruction 74-8 (revised 11/8/78) also contains restrictions and
.
.
limits on Control Room Access. With respect to the licensee's commitment in reference 16, the inspector verified that a new Figure 1 was added to SEPIP Appendix J (Revision 10, 2/27/80) to specify the TSC, ECC and Control Room Management and Communications flow paths.
.
No deviation from ifcensee commitments was identified.
2.1.8.a (II.B.3) Post Accident Sampling
--
The inspector reviewed licensee procedure RCP 1-503, Revision 1, dated April 2, 1980.
The purpose of this procedure is for the timely performance of post accident sampling for chemical and radioactivity analysis of the reactor coolant and containment atmosphere without incurring radiation exposure in excess of 3 rem (whole body) and 18.75 rem (extremity) to any individual. The procedure was developed as an interim measure, t v.g existing sampling systems. A major plant modification is beint instituted to meet the " Category B" requirements for post accident sampling.
The inspector verified that a shield wall with remote handling tools and a mirror for viewing from behind the wall has been installed in the primary coolant sampling rooms.
A cursory review of the procedure indicated tnat implementation of the procedure relies heavily on individual knowledge of the normal sar.pling technique addressed in procedure RCP-1-501, but that procedure is not referenced nor is there a prerequisite for familiarization with this procedure.
In addition, the procedure would not result in a containment air sample being taken by following the steps outlined for sampling if the containment radiation levels were greater than 3000 R/hr, and the procedural steps are inconsistent with the plant design.
The licensee committed to revising the procedure to assure proper containment air sampling.
This item is unresolved (317/80-16-06; 318/80-15-05).
2.1.3.a (II.D.3.) Power Operated Relief and Safety Valve Position.
--
The inspector reviewed the licensee commitments stated in refer-ences 10 and 13. Facility Change Request (FCR) 79-1039 and Preventative-Maintenance (PM) Procedure 64-I-R-13 and associated Control Board alarm procedures.
Pressurizer Relief Valve Acoustic Monitor System function and operation was discussed with licensed operators.
No deviation from licensee commitments was identified.
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2.1.7.a and.b (II.E.1.2) Auxiliary Feed System Actuation and
--
Flow.
The inspector reviewed Facility Change Requests (FCR) 79-1035 and 79-1060, reviewed the operator required reading file and discussed i
current Auxiliary Feedwater (AFW) automatic initiation installation with plant operators.
Safety grade flow indication is installed I
and operational in both units.
Modifications to install safety grade automatic start of AFW pumps on low steam generator lecel
[
are in progress on Unit 1 and are expected to begin in January, l
1SS1, on Unit 2.
The short ters commitment was satisfied by installation of control grade circuitry designed to initiate automatic start of AFW pumps on loss of Feedwater Flow.
The inspector concluded that the licensee has met the commitments stated in reference 10 and expects to meet the commitments of reference 15 in February, 1981.
2.1.1 (II.E.3.1) Emergency Power for Pressurizer Heaters.
--
The inspector reviewed FCR's 79-1056 for Unit 1 and Unit 2 initiated November 8, 1979. The installation work has been completed and FCR package completion is in progress.
Two sets of pressurizer backcp heaters (300 kw each) per unit were transferred to the 480 V Emergency busses (118, 21B, 14B, and 248).
The design included tripping of the breakers in the event of a SIAS signal to protect the Emergency Power sources. Two sets of backup heaters remain powered from non-vital buses and the sets on the vital buses
.
can be locally reset.
The proportional heaters are currently
'
supplied by the vital buses (diesel generator backup).
The inspector observed the installed feeder breakers (4 total) and the near,s for local reset.
Operator training conducted in December, 1979, was reviewed.
Procedures consisting of Main Control Board caution notes to reset the respective backup heaters following an SIAS initiation or under voltage condition were in place and the inspector
!
questioned operators concerning the necessary steps to reenergize l
the heaters. The inspector stated that the temporary nature of the caution note should be corrected and incorporated into permanent
'
plant procedures.
This item is unresolved (317/80-16-07; 318/80-15-06).
2.1.5.c (--) Recombiner Procedure Review and Upgrade.
--
The position on dedicated containment penetrations for hydrogen recombiners does not apply'to Calvert Cliffs, where redundant recombiners are located wholly within the containments.
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2.1.4 (II.E.4.2) Isolation Dependability.
--
The inspector reviewed Facility Change Requests (FCR) 79-1055 and
!
79-1033, Maintet'nce Requests (MR) M-79-7162, E-80-0048, M-80-7005-E, IC-79-21e ', IC-79-131, Installation Procedure M-80-7004-E.2-I and Technice Support Procedure 31 and 32. Changes to associated surveillance test procedures and transmittal of required l
reading to plant operators were also verified.
The inspector concluded that 23 non essential valves, in both Unit 1 and 2,
- _
identified in Reference 8 have been modified to close on a Safety.
Injection Isolation signal (SIAS) to provide diverse isolation on
!
both'high containment pressure and low pressurizer pressure.
These modifications also installed electrical interlock circuitry which requires all valve operating switches to be in the isolated position before SIAS can be reset.
The inspector concluded that the licensee has met the requirements stated in Section 2.1.4 of reference 1 and the commitments made in references 8 and 10. The
l inspector also noted that the instrument air and Reactor Cooling l
Pump (RCP) supply and return cooling water penetrations were not identified as either essential or nonessential in reference 10.
The basis was that RCP cooling water and instrument air flow into containment through check valves and cooling water out of containment
flows into a closed system which is neither part of the reactor l
coolant pressure boundary or connected directly to the containment.
These penetrations will continue to isolate on high containment
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pressure (CIS) only. Individual sample valve overide modifications required for post accident sampling capability are in progress on l
Unit 1. Unit 2 sample valve overides are expected to commenca in January, 1981.
,
!
No deviation from estatlished requirements and commitments was l
identified.
t 2.1.3.b (II.F.2) Instrumentation to Detect Inadequate Core Cooling.
--
Installation of the Subcooled Margin Monitors had previously been inspected (Inspection Report 317/80-08; 318/80-08). During this inspection the inspector noted that, although alarm windows had been installed for the Monitors, Alarm Window Procedures were not
'
in place. The licensee stated that these procedures would be issued.
This item is unresolved. (317/80-16-08; 318/80-15-07).
2.1.1 (II.G.1) Power Supplies for Pressurizer Relief Valves and
--
,
'
Levels.
The inspector rev'ewed the licensee's ccaments and commitments stated in references 8 and 11.
No licensee action was taken l
because the insta'. led equipment met the NUREG position.
No deviation from licensee commitments was identified.
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2.2.2.b (III.A.l.2) Upgrade Emergency Support Facilities.
--
The inspector examined the Technical Support Center (TSC) and found major modifications in progress to upgrade the facility.
Because of these modifications, the three (3) commercial tele-phone lines previously installed had been removed.
The licensee committed to have the phones re-installed with an expected comple-tion during the week of 11/13/80.
The inspector examined the ability of the licensee to obtain the 17 itemized system parameters from the Startup/ Physics Test Panel which has been located in the TSC.
The licensee, in a letter dated November 20, 1979, committed to have this parameter display panel in place by February 15, 1980.
This panel is to provide an interim means for evaluating plant conditions until a permanent
~
system can be installed (part of the on going modifications).
As installed, the panel would rot provide indication of 3 of the 17 parameters (Atmos. dump, turbine bypass, and feedwater regulating valve positions) because one of the two cables needed for the panel operation was not run from the Control Room to the TSC.
Upon identification, the licensee initiated act.ans to have the cable run. Both cables were in place on October 30, 1980.
This item is unresolved (317/80-16-09; 318/80-15-08) pending installation of the three commercial telephones in the TSC.
--
2.2.2.c (III.A.l.2) Onsite Operational Support Center.
'
The inspector verified that the licensee hac provided for an Onsite Operational Support Center, which is located in the old
service building across the turbine deck from the control room.
The Site Emergency Plan has been revised to detail the function and operation of this facility.
No deviation from licensee commitments was identified.
2.1.6a (III.D.1.1) Primary Coolant Outside Containment.
--
l The inspector verified that procedure STP M-573-1 and 2 was
implemented, establishing a leak reduction program.
The procedure l
requires the leak testing of those systems which may contain a i
primary coolant under accident conditions. Per the procedure, all l
leaks are measured, recorded and repaired, if possible.
A frequen-l cy of at least once per 18 months has been established.
The l
licensee is also examining the use of teflon seats to further l
reduce any leakage.
No deviation fiom licensee commitments was identified.
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2.1.8c (III.D.3.3) Inplant Radiation Monitoring.
--
The inspector verified that the licensee has a GE (Li) detects.
with a multi-channel analyzer for use in evaluating charcoal cartridges, which are used for obtaining radiofodine air samples.
Also, the inspector verified the location, in the Control Room
-
Emergency Kit, of a Na(I) detector with a single channel analyzer.
This equipment is to.be used as a backup to the primary analyzer equipment.
The inspector stated that consideration should be given to the use of a silica gel or a silver zeolite sampling media which provides reduced adsorption of noble gases compared to the charcoal cartridges. The licensee acknowledged the inspector's comments.
No deviation from licensee commitments was identified.
2.1.8b (II.F.1) Additional Accident Monitoring.
--
The inspector verified that procedure RCP l-503 incorporated the interim implementation of the requirements for high range effluent monitoring.
This procedure is the same one which implements the post-accident sampling (2.1.8.a).
The procedure calls for obtain-ing direct radiation reading of the radiation monitoring system (main vent) and of the atmosphere steam relief piping, both of which are-located in the Main Plant Exhaust Equipment Room.
The inspector also verified the physical location, in the Control Room Emergency Kit, of a PIC-6A portable dose rate meter which is
-
to be used for the radiation measurements.
The final.implementa-tion of the " Category B" accident monitoring requirements will l
include radiation monitors located on the exterior of the main v,ent with remote readout.
!
No deviation from licensee commitments was identified.
l 10.
l l
a.
Review of Licensee Event Reports (LER's)
The inspector reviewed LER's submitted to the Ni.3.RI office to verify that the details of the event were clearly reported, including the accuracy of the description of cause and adequacy of corrective action.
i
' The inspector determined whether further information was required from l
the licensee, whether generic implications were indicated, and whether the event warrr.nted onsite follow-up.
The following LER's were reviewed:
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LER No.(Unit No.)
LER Date Event Date Subject
- 80-058/IT (2)
November 11, 1980 October 21, 1980 No. 11 & 12 A/C Plants out of service
- 80-039/3L(1)
September 15, 1980 August 15, 1980 No. 12 A/C Plant out of service
- 80-048/IT (1)
September 4, 1980 September 3, 1980 No. 11 & 12 A/C Plants out of service
- 80-049/3L (1)
September 26, 1980 August 30, 1980 No. 12 A/C Plant out of service
- 80-051/IT (1)
September 26, 1980 September 11, 1980 Loss of No. 11 & 12 A/C Plants
^80-034/IT (1)
July 30, 1980 July 16, 1980 No. 11 & 12 A/C Plants out of service
- 80-038/3L (1)
August 29, 1980 August 1, 1980 No. 12 A/C Plent out of service
'
- 80-029/3L (1)
July 18, 1980 June 16, 1980 No, 11 A/C Plant out of service
- 80-028/3L (1)
June 13, 1980 May 15, 1980 No. 12 A/C Plant out of service
- 80-018/3L (1)
April 30, 1980 April 1, 1980 No. 11 A/C Plant out of service
- denotes reports selected for onsite follow-up.
a.
For the LER's selected for onsite review (denoted by asterisks above), the inspector verified that appropriate corrective action was taken or responsibility assigned and that continued operation of the facility was conducted in accordance with Technical Specifications and did not con-stitute an unreviewed safety question as defined in 10 CFR 50.59.
Report accuracy, compliance with current reporting requirements and applicability to other site systems and components were also reviewed.
Control Room Air Conditioning.
--
The licensee has submitted ten LER's reporting Control Room Air Conditioning out of service since April 1980.
Four of these occurrences resulted in a complete loss of air condition-ing to the Control Room.
The remaining seven involved correc-tive maintenance and unit trips. The licensee attributes these
_
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j persistent problems to oil migration, improper refriger-ant flow when low outside temperature occurs, and to
'
ir. ability to maintain design conditions during periods of high summer temperatures.
Licensee engineering studies combined with studies conducted by a consulting firm (WKR, Inc.) and update of heat load calculations resulted in the determination that the system is about 10% (10 tons) deficient in cooling capacity.
Facility Change Requests (FCR) 80-51 and 80-06 have been issued to upgrade the refrigerant pressure control valves, install oil separators and modify the pneumatic cantrol system.
These FCR's are expected to improve system reliabili+.y. The licensee is considering several proposals to improve system capacity, such as improved insulation, lighting level modifications in areas adjacent to the control room and addition or replacement of air conditioning plants.
This is an open item (317/80-16-10, 318/80-15-09).
11.
Review of Periodic and Special Reports Upon receipt, periodic and special reports submitted by the licensee pursuant to Technical Specification 6.9.1 and 6.9.2 were l
reviewed by the inspector.
This review included the following I
considerations: The report includes the information required to l
be reported by NRC requirements; test results and/or supporting l
information are consistent with design predictions and performance specifications; planned corrective action is adequate for resolution
>
of identified problems; determination whether any inforn:ation in the report should be classified as an abnormal occurrence; and the validity of reported information. Within the scope of the above, the following periodic reports were reviewed by the inspector:
September 1980 Operations Status Reports for Calvert Cliffs
--
No.1 Unit and Calvert Cliffs No. 2 Unit, dated October 15,
,
1980.
12.
Unresolved Items j
Unresolved items are matters about which more information is
.
required to determine whether they are acceptable, items of
'
'
noncompliance or de/iations.
Unresolved items addressed during l
this inspection arc discussed in Paragraphs 2, 9 and 10 of this l
report.
,
13.
Exit Interview
,
i i
Meetinas were held with senior facility management periodically l
,
l during the course of this inspection to discuss the inspection
!
scope and findings.
A summary of inspection findings was also
provided to the licensee at the conclusion of the report period.
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