IR 05000317/1981012
| ML20010B970 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/29/1981 |
| From: | Blumberg N, Caphton D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20010B965 | List: |
| References | |
| 50-317-81-12, 50-318-81-12, NUDOCS 8108180548 | |
| Download: ML20010B970 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
50-317/81-12 Report No.
50-318/81-12 50-317 Docket No.
50-318 DPR-53 License No.
DPR-69 Priority
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Category C
Licensee:
Baltimore Gas and Electric Company P. O. Box 1475 Baltimore, Maryland 21203 Facility Name:
Calvert Cliffs Units 1 and 2 Inspection at:
Lusby, Maryland
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Inspection conducted:
May 18-22, 1981
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Inspector:,
N. Blumberg, React r I ector
'date ' signed b
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Approved by:
/fd /k M
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Donald L. daphfon, Chief Management
'date' signed Programs Section Inspection Summary:
Inspection on May 18-22, 1981 (Combined Inspection Report 50-317/81-12 and 50-318/81-12)
Areas Inspected:
Routine, unannounced inspection by one region based inspector of administrative controls for safety related calibrations and surveillance; program and implementation for Technical Specifications surveillance calibra-tions and functional tests; program and implementation for calibration of plant instruments which verify Technical Specification surveillance tests and in-service inspection tests; program and implementation for calibration of test and measurement equipment; program and impleinentation for Technical Specifi-cation surveillance testing; and implementation of inservice inspection pro-gram for pumps and valves. This inspection involved 38 inspector-hours onsite by one region-based inspector.
Results: Noncompliances - none in five areas and one in one area (Violation -
Failure to calibrate safety related test gauges, Paragraph 4.c(1)).
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Region I Form 12 (Rev. Apr 77)
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8108180548 810803 PDR ADOCK 05000317 O
POR
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DETAILS 1.
Persons Contacted
- J. Carroll, General Supervisor, Operations S. Davis, Senior Engineer for Operations
- W. Gibson, General Supervisor, Electrical and Controls (E&C)
L. Hinkle, Unit 1 Instrument and Controls (I&C) Supervisor P. Rizzo, Engineering Analyst, E&C Section
- L. Russell, Plant Superintendent G. Sack, Supervisor of Test Equipment
- S. Somma, Nuclear Fuel Management Engineer J. Steeleman, Nuclear Fuel Management Engineer R. Sydnor, E&C Section Surveillance Test Coordinator USNRC
- R. Architze', Senior Resident Reactor Inspector The inspector also interviewed other licensee personnel including reactor operators and members of the clerical staff.
- Denotes those present at the exit interview.
2.
Admiriistrative Controls for Safety Related Calibrations and Surve111ances Administrative controls governing the performance of safety related
calibrations and surveillances were inspected to determine their conformance with the requirements of 10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants;"
Technical Specification, Section 6, ' Administrative Controls;" ANSI 18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants;" and Regulatory Guide 1.33, Revision 2, 1978, " Quality Assurance Program Requirements (Operation)".
The following procedures were reviewed.
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QAP-13, In-Service Inspection, Revision 7, January 23, 1981.
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QAP-16, Surveillance Testing, Revision 13, May 11, 1980.
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QAP-17, Control and Calibration of Measuring and Test Equipment,
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Revision 14, Match 9, 1981.
Calvert Cliffs Instruction (CCI) 104E, Surveillance Test Program,
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July 15,1980, Change 9, April 24, 1981.
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CCI-1148, Plant Logs, March 18, 1981.
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CCI-1198, Shop / Lab Memos, July 10, 1980.
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CCI-120B, Calibration Program for Measuring and Test Equipment,
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July 1,1980.
CCI-135A, Administration of In-Service Inspection, May 13, 1980.
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CCI-204C, Functional Test Procedures, July 15, 1980.
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CCI-205E, Setpoint Control Procedure, July 14, 1980, Change 2,
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April 6, 1981.
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CCI-2098, Test Equipment Calibration Procedures, July 15, 1980.
CCI-211C, Preventive Maintenance Program, August 27, 1980.
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CCI-212C, Precision Tool Calibratian and/or Testing, August 28,
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1980, Change 1, February 18, 1981.
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CCI-301, Recording of Plant Transients /Operatienal Cycles, Feb,*uary 14, 1974, Change 7, July 1,1980.
CCI-303B, Operations Preventive Maintenance Program, July 2,
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1980, Change 1, February 18, 1981.
No items of noncompliance were identified.
3.
Program and Implementation Required by Technical Specifications for Instrument Functionai Tests, Surveillance Calibrations and i
Calibration Checks
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l a.
An inspection was conducted on a sampling basis of the program and its implementation required by the Technical Specifications for surveillance calibrations, and calibration checks and instrument functional tests of components. -The program wa,s. inspected
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for~conformance to the requirements of ANSI N18.7-1976, "Adminis-l.
trative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" and Regulatory Guide 1.33-1978, " Quality
Assurance Program Requirements (Operation)". Additionally, the
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i program was inspected for implementation in accordance with the above standards and the appropriate plant administrative require-ments detailed in paragraph 3.
The following areas were also
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verified:
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A master schedule has been established for surveillance
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calibration testing:
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Responsibilities have been assigned for performance of surveillance calibrations and to :ssure that calibration schedules are satisfied;
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Methods and responsibilities have been established for
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review and evaluation of calibration' data, for reporting calibration deficiencies and failures, and for verification that LC0 requirements have been satisfied;
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Applicable system status during component calibrations was in conformance with Technical Specification limiting condition for operations, where applicable;
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Procedure format provided detailed stepwise instructions in the degree of detail necessary fr-e performing the calibra-tions;
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Procedure review and approval were as required by Technical Specifications;
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The technical content of procedures was sufficient to result in satisfactory component calibration and Technical Specifi-cation limits and setpoints were complied with; and Calibration data was adequately and accurately recorded and
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was within established tolerances.
b.
The following procedures were reviewed:
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STP M-536-1, Containment Sump Level Calibration, Revision 2, September 17, 1980.
Data reviewed for tests completed November 7, 1980 and January 6, 1979.
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STP M-512-1, Incore Instrument Calibration, Revision 3,
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August 29, 1979. Data reviewed for tests completed December 22, 1980 and July 9,1979.
STP 0-63-1, Remote Shutdown Instrument Channel Check, Revision
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6, July 5, 1978. Data reviewed for test of pressurizer level instrument tests completed April 17, 1981; March 17, 1981; and February 17, 1981.
STP 0-63-2, Remote Shutdown Instrument Channel Check, Revision
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5, July 5, 1978. Data reviewed for reactor coolant cold leg temperature tests completed May 10, 1981; April 10, 1981; and March 7, 1981.
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STP M-2108-1, Reactor Protective System Functional Test, Revision 16, February 10, 1981,Section IX, Axial Power
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Distribution Channel Test. Data reviewed for tests completed April 11,1981; March 2,1981; -and February 14, 1981.
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I-9, Reactor Protective System Flow Setpoint Calculation, Revision 5, October 12, 1979.
Data reviewed for tests completed March 9, 1981 and February 28, 1980.
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STP M-460-0, Seismic Accelerometer Calibration, Revision 0, August 4, 1976. Data reviewed for tests completed September 22, 1980; and March 17, 1980.
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STP M-560-0, Seismic Instruments Calibration, Revision 2, August 19, 1976.
Data reviewed for tests completed October 30, 1980 and May 8, 1979.
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STP M-461-0, Meteorological Calibration, Revision 1, July 27, 1976.
Data reviewed for tests completed October 22, 1980 and May 9, 1980.
No items of noncompliance were identified.
4.
Calibration of plant Installed Instrumentation Associated With Verification of Technical Specification Surveillance Tests-Program and Implementation a.
A selective sampling inspection was conducted of the program and its implementation for calibration of plant installed instrumen-tation used to verify satisfactory performance of Technical Specification surveillance tests or Inservice Testing.
The program was inspected for conformance to the requirements of ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" and Regulatory Guide 1.33-1978, " Quality Assurance Program Requirements (Opera-tions)". Additionally, the program was inspected for implementation in accordance with the above standards and the appropriate plant administrative requirements detailed in paragraph 3.
The following areas were verified:
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A master schedule has been established for calibration testing;
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Responsibilities have been assigned for performance of cali-brations and to assure that calibration schedules are satis-fied;
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Calibration schedule and frequencies as established by the licensee are being followed;
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Procedures have been reviewed and approved in accordance with Technical Specifications, contain acceptance criteria consistent with Technical Specification requirements and contain detailed instructions commensurate with the complexity of the calibration;
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The technical content of procedures is adequate to perform
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satisfactory calibration; and
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Calibration data was adequately and curately recorded and was within established tolerances.
b.
The following procedures were reviewed:
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M-532-1, Pressurizer Level IC-43 Calibration, Revision 5, September 17, 1980.
Data reviewed for tests completed November 19, 1980 and May 8, 1979.
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M-530 !, RCS Cold Leg Temperatu.e Calibration, Revision 2, Octobe.- 10, 1979.
Data revieved for tests completed October 30, 1980; May 25, 1979; and /pril 29, 1979.
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Generic Procedure FTI-105, Loop Calibration Check Procedure, Revision 2, July 20,1979. Associated data sheets reviewed for the following tests:
(1) 1-LIC-266, Volume Control Tank Level Calibration, completed June 16, 1980; (2)
F-210-Y, Boric Acid Flow Integrator Calibraticn, completed November 22, 1980; (3)
F-210-X, Reactor Coolant Makeup Flow Integrator, completed November 7, 1980; (4) 1-LI-42E9, Reactor Coolant Drain Tank Level Calibration, completed November 6, 1980.
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Generic Procedure FTI-107, Flow Transmitter Calibration /Cali-bration Check Procedure, Revision 1, July 20, 1979. Associ-ated data sheets reviewed for the following test:
1-FT-2540, CVCS Letdown and Charging Diversion Flot Integrator Calibration completed May 28, 1980 and August 28, 1980.
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Generic Procedure FTI-101, Alarm /Setpoint Procedure, Revision 1, July 20, 1979. Associated data sheets reviewed for the folicwing tests:
(1) 1-FT-210X, Primary Makeup Flow Alarm Calibration, completed November 10, 1980; (2) 0-LS-4822, No. 12 Diesel Generator Fuel Oil Day Tank Low Level Alarm Calibration, completed September 23, 1980.
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Generic Procedure I-106, Receiver Calibration / Calibration
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Check Procedure, Revision 2, July 20,1979. Associated data sheet reviewed for the following test:
0-FI-6223, Fire Protection Pretreat Water Recirculation Flow, completed October 21, 1980.
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PMS 1-24-E-P-4, Metering Calibration Diesel Generators 11, 12 and 21. Associated data sheets reviewed fcr the following tests:
Calibration of No. 11, No. 12, and No. 21 Diesel Generator
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Kilowatt Meters, completed October 31, 1980.
c.
Findings
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(1) 10 CFR 50, Appendix B, Criterion XII, and Regulatory Guide
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1.33, Appendix A, require that safety related readout instru-ments be periodically calibrated. The licensee was unable to provide to the inspector calibration records for gauges which were used to verify the operability of safety related pumps to meet Technical Specification and Inservice Inspection.
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requirements.
The following are examples of gauges whose
accuracy could not be confirmed and which vere used in the performance of STP 0-70-1, " Engineered Safety Features
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Eouipmen'. ?erformance Test",
Salt Water Pump No. 11 Discharge Pressure Gauge;
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HPSI Pump No. 11 Suction Pressure Gauge;
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Boric Acid Pump No. 11 Discharge Pressure Gauge; i
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Service Water Pump No. 11 Discharge Pressure Gauge.
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A licensee represertative stated that test' gauges had been installed to perform surveillance and ISI testing.
He further stated that these gauges were in calibration when installed; however, through an oversight the gauges were left installed and not recalibrated at periodic intervals.
Additionally, the licensee representative stated that the problem was programmatic in that it applied to all installed gauges used for pump surveillance and not just to the examples i
noted above. The inspector determined through discussions v.ith licensee's representatives that although the examples-
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noted above wert in Unit No. 1 the problem was applicable to i
Unit No. 2 alse.
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Failure to calibrate test gauges used to verify operability of safety related pumps is contrary to 10 CFR 50, Appendix B, Criterion XII; BG&E QA Policy-1; and Regulatory Guide 1.33-1978 and constitutes an item of noncompliance (50-317,71-12-01 and 50-318/81-12-01).
(2) Generic Procedure FTI-107, Flow Transmitter Calibration /Cali-bration Check Procedure, states that all eleven data points shown on the data sheet should be used when performing the calibration of flow transmitters.
For the calibrations of 1-FT-2540, CVCS Letdown and Charging Diversion Flow Integrator performed May 28, 1980 and August 28, 1980, the inspector observed that calibrations were conducted using only every second data point.
A licensee representative stated thst the procedure should have been written to allow the option of using every other data point for calibrations. He also provided to the inspector other generic procedures which allowed for this option. The licensee representative further stated that failure to include this option in FTI-107 had been an oversight. The inspector independently determined, by review of the data points, that an adequate calibration could be provided using every other data point.
The licensee stated that FTI-107 would be revised by July 31, 1981, to allow the option of using every other data point for the calibration. This item is unresolved pending licensee action and subsequent NRC:RI review (317/81-12-03 and 318/81-12-03).
5.
Calibration and Control of Test and Measurement Equipment-Program and Implementation An inspection was conductea to determine the adequacy of calibration and control of test and measuring equipment.
The program was inspected for conformance to ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" and Regulatory Guide 1.33-1978, " Quality Assurance Program Requirements (Operation)" and ANSI N45.2.4, " Installation, Inspection and Testing Requirements for Instrumentation and. Electric Equipmer+. During the Construction of Nuclear Power Generating Stations."
Additionally, the program was inspected for implementation in accordance with the above standards and the appropriate plant administrative requirements detailed in paragraph 3.
The following areas were veri-fied:
Establishment and maintenance of a master test equipment list;
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Establishment and adherence to calibration schedule;
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Test equipment was in calibration when in use;
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Calibration data, where available, was adequate and accurate and
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within s;.ecified tolerances; Maintenance of calibration records identifying standards used
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which have traceability to the National Bureau of Standards or other testing organization,
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Test equipment custody control records;
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Storage and labeling of test equipment;
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Test equipment used as primary standards for in plant calibrations of test equipment were in calibration;
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Traceability of out of calibration test equipment to usage of that equipment;
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Establishment of responsibilities for control of test equipment; and,
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Control and calibration of eight pieces of test equipment used for calibration or test of components identified in paragraphs 4.b, 5.b, 7.b and 8.b.
c.
Findings No items of noncompliance were identified; however, the following inspector concern was identified and resolved during the inspection:
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In order to assure traceability of use of test equipment in case test equipment is found to be out of calibration, the licensee has developed a system in which the technician who uses the equipment also logs its Jse to a procedure or job number.
The inspector observed two instances in which tech-nicians, ore from Unit 1 and the other from Unit 2, failed tc log the instrument usage. Based on further inspection of
this area, the above two instances appeared to be isolated
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cases. The inspector had no further questions in this area.
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6.
Surveillance Testing Required by Technical Specifications-Program and Implementation a.
An inspection was conducted, on a sampling basis, of the program and its implementation for the surveillance testing of equipment and systems as required by the Technical Specifications. The program was inspected for conformance to the requirements of ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" and Regulatory Guide 1.33-1978, " Quality Assurance Program Requirements (Operation)".
Additionally, the program was inspected for implementation in accordance with the above standards and the appropriate plant administrative requirements detailed in paragraph 3.
The following areas were verffied:
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A master schedule has been established for surveillance testing; Respocsibilities have been assigned for performance of tests
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and to assure that test schedules are setisfied;
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Methods and responsibilities have been established for review and evaluation of test data, for reporting test deficiencies and failures, and for verification that LC0 requirements have been satisfied;
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Tests required by Technical Specifications are available and covered by properly approved procedures;
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Test format and technical content are adequate and provide satisfactory testing of related systems or components;
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Tests have been reviewed as required by facility administri-tive requirements: and,
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Tests were performed within the time frequencies specified by the Technical Specifications and appropriate action was taken for any item failing acceptance criteria.
b.
The following surveillance tests and data for completed tests were reviewed:
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STP 0-73-1, Engineered Safety Features Equipment Performance Test, Revision 12, October 15, 1980.
Data reviewed for the following tests:
(1) 9eric Acid Pump operability tests completed April 13, 1981; March 10, 1981; and February 12, 1981; and,
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(2) Charging Pump operability tests completed April 13, 1981; March 10, 1981; and February 12, 1981.
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STP M-471-2, Air Lock Door Operability and Leak Rate Test,
Revision 3, January 9, 1981. Data reviewed for tests completed March 3,1981 (Door Interlock Portion Only); December 22,
1980; and May 15, 1980.
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STP M-171-1, Personnel Air Lock Seal Test, Revision 2, February 1, 1979. Data reviewed for tests completed April 16, 1981; May 8, 1981 and April 10, 1981.
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STP 0-27-2, RCS Leakage Evaluation, Revision 3, November 14, 1980. Data reviewed for daily leakage evaluation tests
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performed daily for the months of April, March, and January, 1981 which were completed April 30, 1981; March 31, 1981; and February 1, 1981 respectively.
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STP 0-64-1, Check of Safety Injection Tank Feeder Breakers, Revision 3, March 25, 1981. Data reviewed for tests completed April 16, 1981; March 16, 1981; and February 16, 1981.
c.
Findings No items of noncompliance were identified; however, the following unresolved items were identified and are discussed below:
(1) ANSI 18.7-1976, paragraph E.3.4.4, specifies that the moni-toring of plant parameters be covered by operating procedures.
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The inspector observed that Control Room logs which, in I
part, monitor plant parameters as required by the Technical Specifications were not part of any approved procedure.
f The licensee noted that the use of plant logs was covered by administrative procedure CCI-114B, " Plant Logs", and that
the Quality Assurance Program states that surveillance
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procedures are not required for surveillances scheduled at or more frequently than every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The inspector concurred that a step-by-step procedure would not be required to log plant parameters but. informed the licensee that tie administrative procedure CCI-114B on how to maintain plant logs did not meet the requirement of ANSI 18.7 and, because of the safety related information contained in the logs, they must be issued and revised in such a manner so as to
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i ensure review by the PORC and approval by the Plant Superintendent as required by Technical Specifications 6.8.1, 6.8.2, and 6.8.3.
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The licensee's representative stated that logs which monitor safety related parameters would be issued as part of an approved procedure by July 31, 1981.
This item is unresolved pending licensee action and subsequent NRC:RI review (317/81-12-02 and 318/81-12-02).
(2) The Technical Spectiications require monitoring of wind speed at both the 125 feet and 200 feet elevations The Control Room recorder, which previously monitored both wind speed and turbulence, has been modified to now record wind speed only.
The inspector observed that the recorder scale for 200 feet elevation wind speed recorder still reads in units of turbulence although the recorder is actually recording wind speed. Correct wind speed, however could be determined by Control Room Operators by counting scale divisions and comparing them to equivalent divisions on the 125 foot elevation recorder which has a wind speed scale.
The licensee's representative stated that the correct indicator scale would be placed on this recorder chart.
Corrective action for this item will be reviewed during a subsequent NRC:RI inspection (317/81-12-04 and 318/81-12-04).
(3) Technical Specification, Appendix B, Section 2.3.B.5, states, in part, that continuous releases of gaseous wastes shall be measured continuously and recorded. The flow rate is con-tinuously monitored and recorded using a differential pressure (D/P) instrument. Conversions from D/P to flow rate is accomplished using a conversion graph posted near the D/P instrument in the stack area. The inspector questioned the r
licensee as to the accuracy and derivation of the chart conversion. A licensee representative stated that this chart was probably installed when the D/P instrument was installed but was unable to document its origin or accuracy during this inspection.
The inspector informed the licensee that the accuracy.of conversion charts used to monitor Technical Specificatien parameters must be verifiable. The licensee stated it would continue efforts to verify the accuracy of charts and intends -
to resolve this item by July 31, 1981. This item is unresolved pending licensee action and subsequent NRC:RI review (317/81-12-05; 318/81-12-05).
7.
Inservice Inspection Program Pumps and Valves-Implementation a.
An inspection was conducted, on a sampling basis, for the imple-mentation of the licensee's Inservice Inspection Program (ISI),
Pumps and Valves. The ISI program implementation was inspected
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for conformance to the licensee's current program submittal, the Technical Specifications Sections 3 and 4, an the appropriate plant administrative requirements detailed in paragraph 3.
Inservice Inspection of Pumps is incorporated into the Technical Specifications and the testing of pumps is addressed in paragraph 6 above. The following valves were selected at random from the licensee's ISI program s'abmittal to determine if appropriate pro-cedures were established for testing these valves:
SI-660, Minimum Flow Recirculation to the Refueling Water
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SI-663, Shutdown Cooling Recirculation to No. 13 HPSI Pump CVC-516CV, Letdown Stop
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CVC-235, Boric Acid Direct Feed Check Valve j
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FW-133, Steam Geneator No. 21 Feed Water Header Inlet Check Valve CVC-210, No. 21 Concentrated Boric Acid Tank Outlet Stop
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i N2-347, Nitrogen to Safety Injection Tank Check Valve
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The inspector determined that test procedures for the above valves were established. These procedures were reviewed for the following:
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Tests were in conformance with inservice test program require-
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i Test frequency was in conformance with Technical Specifica-
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tions and the Inservice Test Program.
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Test'results were required to be reviewed as required by facility administrative requirements and appropriate action was required to be taken for results failing acceptance criteria.
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b.
The following procedures were reviewed:
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STP 0-65-1, Quarterly Valve.._0perability Verification -
Operating, Revision 13, December 5, 1980. Verified opera-bility of valves SI-660 and SI-663.
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STP 0-66-1, Quarterly Valve Verification Shutdown, Revision 6, January 23, 1981. Verified operability of valve CVC-516C.
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STP 0-67-2, Check Valve Operability Verification, Revision 5, November 21, 1980. Verified operability of valves CVC-235 and FW-133.
STP 0-93-2, Locked Valve Verification, Revision 4, March 6,
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1981. Verified status of CVC-2 G.
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STP M-571-2, Local Leak Rate Test, Revision 7, September 24, 1980. Verified operability of N2-347.
No items of noncompliance were identified.
8.
Unresolved Items Unresolved items are matters about which more information.s required
in order to ascertain whether they are acceptable, deviations, or items of noncompliance. Three unresolved itemr were identified during this inspection and are detailed in paragraphs 4.c.(2), 6.c(1), and 6.c(3) above.
9.
Management Meetings Licensee management was informed by the scope and purpose of the inspection at the entrance interview conducted on May 18, 1981.
The findings of the inspection were periodically discussed with licensee representatives during the course of the inspection. An exit interview was conducted on May 22, 1981, see paragraph 1 for attendees, at which time the findings of the inspection were presented.
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