IR 05000317/1982015

IE Insp Rept 50-317/82-15 on 820616-18,21 & 22.Noncompliance Noted:Failure to Adequately Control Work on safety-related Sys & Failure to Establish Adequate Procedures to Maintain Containment Integrity

ML20062H472
Person / Time
Site:	Calvert Cliffs
Issue date:	07/19/1982
From:	Bettenhausen L, Rekito W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20062H329	List: IR 05000317/1982015 ML20062H324 ML20062H331
References
50-317-82-15, NUDOCS 8208160063
Download: ML20062H472 (10)

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U.S. NUCLEAR REGULATORY COMMISSION Region I Report N /82-15 Docket N License N DPR-53 Priority --

Category C Licensee: Baltimore Gas and Electric Company P. O. Box 1475 Baltimore, Maryland 21203 Facility Name: Calvert Cliffs Nuclear Power Plant, Unit-1 Inspection At: Lusby, Maryland Inspection Conducted: June 16-18, 21, 22, 1982 Inspectors: [/ @[.f W. A. Rekito(/ Reactor Inspector 7 /e/ / 2-

' Da't'e Approved by: MIY/ s~

L. H. Be'ttenhausen, Chief, Test

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Programs Section, Engineering Programs Branch Inspection Summary:

Inspection on June 16-18, 21, 22, 1982 (Report No. 50-317/82-15)

Areas Inspected: Routine, unannounced inspection of the containment penetration leakage testing program, the containment integrated leakage rate test, tours of facility and follow-up on previous inspection finding The inspection involved 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> on site by one region based NRC inspecto Results: Two violations were identified:

(1) Failure to adequately control work on a safety related system

(Paragraph 5).

(2) Failure to establish adequate procedures to maintain containment integrity (Paragraph 6).

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DETAILS Persons Contacted The technical and supervisory personnel listed below were contacte l M. Burgess, ILRT Engineer - Bechtel

• J. Doswell, Engineer, Technical Support .

• W. Gibbson, General Supervisor, Electrical and Controls 1 4 *R. Heibel, Principal Engineer, Technical Support M. Lavin, Engineer, Technical Support -

L. Russel, Plant Superintendent J. Sites, I & C. Supervisor R. Sydnor, Surveillance Test Coordinator  :

• R. Wenderlich, Senior Engineer - Operations M. Zieman, Control Technician i

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, NRC Personnel R. Architzel, Senior Resident Inspector D. Trimble, Resident Inspector  ;

The inspector also talked with and interviewed other licensee personnel during the inspectio They included members of the operating and technical staff * denotes those present at the exit interview on June 22, 198 . Follow-up on Previous Inspection Findings (0 pen) Unresolved Item (317/82-07-07): Evaluation of containment leakage

! improvements performed prior to the Containment Integrated Leakage Rate

Test (CILRT). The licensee plans to evaluate all leakage improvements in l conjunction with the CILRT results to make a determination (best assessment)

of the containment system overall leakage at the end of operating Cycle This evaluation will be described in the CILRT Technical Summary Report submitted to the NRC. This item will remain open pending NRC review of the licensee's completed evaluatio . Containment local Leakage Rate Testing (LLRT)

f 3.1 Documents Reviewed

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STP M-571-1, Revision 4, Local Leak Rate Tests

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STP M-172-1, Revision 4, Personnel Escape Lock Seal Test

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STP M-171-1, Revision 4, Personnel Air Lock Seal Test i

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STP M-471-1, Revision 4, Air Lock Door Operability and Local Leak Rate Test

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Records of Local Leakage Rate Testing (LLRT) activities conducted during the recent outage including test results, related repair and retest documentatio Selected system drawings, Piping and Instrumentation Diagram .2 Scope of Review The inspector reviewed the above documents to ascertain compliance with regulatory requirements of 10 CFR 50, Appendix J, Calvert Cliffs Technical Specifications, and applicable Industry Standard The inspector also witnessed a local leakage rate test, reviewed qualifications of test personnel, and held discussions regarding the importance of quantifying the "AS FOUND" leakage condition during LLRT activities. Further details are described belo .3 Test Results The inspector reviewed the LLRT results summary and discussed analysis of test failures, repairs, and retests with the licensee. All LLRTs were completed prior to the start of the CILRT. The inspector noted that the initial tests on several containment isolation valves (CIVs) exceeded the licensee's administrative leakage limit, were repaired and retested. These problems did not present a total containment system degradation because in each case either the initial leakage was not excessive or leakage past the redundant leakage limiting barrier was not excessive. The inspector explained that the overall containment system leakage improvements resulting from these repairs and others prior to the CILRT are expected to be added to the results of the CILRT for determination of the "AS IS" test results in accordance with 10 CFR 50, Appendix J. This require-ment was acknowledged by the licensee and preliminary evaluations of LLRT results for this purpose appeared to be adequat .4 Test Witnessing On June 17, 1982, the inspector witnessed a Type B LLRT of the Personnel Escape Lock door seals. The test was conducted in accordance with procedure STP-M-172-1 using a Volumetric Leak Rate Test Monito The results of the test were considered acceptable with a measured j leakage of 1.1 SCCM for the inner door and 2.1 SCCM for the outer

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The inspector verified that the test was being conducted in accordance with the approved procedure and that the test instruments were properly calibrated. Additionally, the inspector interviewed several-test technicians to ascertain that they were knowledgeable of test procedure requirements and use of the special test instruments. No unacceptable conditions were identifie . Containment Integrated Leakage Rate Test (CILRT)

4. :i General On June 19-21, 1982, Calvert Cliffs Unit 1 performed their second periodic CILRT as required by TS 3/4 6.1.2. The test was conducted at a peak accident pressure of 50 psig in accordance with procedure STP M-662-1, Integrated Leak Rate Test Unit 1 Containment. The inspector reviewed the test procedure, witnessed preparations and various portions of the test, verified qualifications of test personnel, and performed independent calculations of test result Further details and inspection findings are described belo .2 Procedure Review The inspector reviewed the CILRT procedure along with documents listed in paragraph 3.1 for technical adequacy and to ascertain

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compliance with requirements of Technical Specifications and 10 CFR ,

50, Appendix J. The inspector noted that the procedure required a '

minimum test duration of eight hours. This reduced duration test is acceptable to the NRC based on the procedure meeting the requirements of Bechtel Power Corporation's Topical Report BN-TOP-1, " Testing ;

Criteria for ILRT of Primary Containment Structures for Nuclear Power Plants." The procedure referenced and was in general conformance with industry standard ANS/ ANSI 56.8-1981, Containment System Leakage Testing Requirement No significant deficiencies were identified. However, the inspector questioned the adequacy of procedural guidance for collecting anc'

evaluating various water levels during the tes It is required to correct the calculated leakage rate for any recognized changes in the containment free air volume. The licensee acknowledged and satisfied the inspector's concern by executing a procedure change which assured appropriate corrections to the calculated leakage rate prior to comparison with the acceptance criteri ,

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S 4.3 Test Boundaries On a random sampling basis, the inspector reviewed the procedure valve lineups for approximately 25 percent of the piping penetration This review was to ensure that systems were properly vented and drained to expose the CIVs to containment atmosphere and test differen-tial pressure with no artificial leakage barriers. No problems or unacceptable conditions were identifie .4 Instrumentation The inspector reviewed the calibration records for the resistance temperature detectors (RTDs), dewpoint instruments, precision pressure detectors, and verification test flowmeters. Their calibrations prior to the CILRT were found to meet applicable accuracy requirements and were traceable to the National Bureau of Standards. During a tour of the containment building, the condition of several instrument sensors was examined. The inspector also verified that the instrumenta-tion system specified in the test procedure satisfied the instrument selection guide of ANS/ ANSI 56.8-1981. No unacceptable conditions were identified with the instrumentation revie .5 Inspection Tours The inspector conducted inspection tours with licensee personnel during the CILRT. During these tours, the general condition of the containment was examined for structural defects, test boundaries were surveyed for evidence of leakage and, on a sampling basis, selected valves were verified to be in the correct positions according to procedure requirements. No unacceptable conditions were identified during these tours. However, the licensee discovered two significant problems previousl While initially pressurizing the containment, excessive leakage was identified through the Fuel Transfer Tube (Penetration 42) and the Containment Heating System supply and return lines (Penetration 62 &

64). As permitted by procedure section I.9, these leak paths were isolated and the test continue The Fuel Transfer Tube leakage was reduced first by re-adjusting the Fuel Pool Side manual gate valve 1-FSTX29M3 and later stopped by installing a cap on drain valve 1-SFP-906 located inside the contain-ment. The inspector noted that the gate valve was not considered a CIV and that the official containment boundary for penetration 42 was the Transfer Tube blank flange and the drain valve which bypasses i .- . .. - . . . .

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The leakage through penetrations 62 and 64 was reduced by extending test boundaries to include a manual valve PH-630 located downstream

, of PH-6579 M0V and a manual valve PH-629 located upstream of check valve PH-376. The licensee explained that this change would not require an LLRT correction to the CILRT results because the FSAR describes both valves PH-630 and PH-629 as additional CIVs. The

inspector confirmed this and also verified that these valves are specified as normally shut in the Plant Heating System, 01-40, ;

Revision 3 and the Cor.tainment Integrity Verification procedure STP '

O.55-1. The inspector stated that this justification appeared to be

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i acceptable but, if credit is taken for these additional manual CIVs,

they would have to be included in the Type C LLRT progra ;

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The licensee acknowledged the inspector's comments and stated his

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4 plan to perform LLRTs to quantify the initial test leakage through

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penetrations 42, 62, and 64 as required by the test procedure and then determine the appropriate corrective actions and test results evaluatio The licensee's handling of these three isolated leakage paths i f considered an unresolved item pending NRC review of the licensee's completed evaluation as described in the CILRT Technical Summary Report. (317/82-15-01) i 4.6 CILRT Chronology l June 19 ----

Completed test preparations and the containment inspectio Commenced pressurizatio .

1630 RCS level indication decreasin ,

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1750 Entered containmen Removed hose from pressurizer [

vents which corrected the level indication proble r

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Conducted leak survey '

1830 Excessive leakage identified through Containment Heating System penetrations 62 and 64.

i 2100 Excessive leakage identified through the fuel transfer tube.into the spent fuel pool.

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Depressurized to 11.5 psi Entered containment. Installed pipe cap at drain valve on fuel transfer tub Changed valve line-up to extend test boundaries for Containment Heating Syste Commenced presstrization agai Leak surveys continue Completed pressurization at 50.1 psi Started temperature stabilizatio June 21 0200 Completed temperature stabilizatio Began taking official LR test dat Completed official test period data collection.

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1415 Commenced supplemental verification tes June 22 0000 Changed arrangement of flowmeter for verification tes Commenced supplemental verification test agai Completed verification test and commenced depressurizing the containmen .7 CILRT Results The licensee evaluated the test results for the eight hour period

between 0545 and 1345 on June 21, 1982. The calculated leakage rate at the upper 95% confidence limit was 0.026 weight percent per da The test acceptance criterion is 0.150 weight percent per da The inspector noted that the above calculated leakage rate did not include corrections for changes in free volume, penetrations in use

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during the test, and leaks isolated during the test. Additionally, this value represents the containment system "AS LEFT" overall

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leakage. An evaluation of leakage improvements resulting from l repairs and replacements prior to the CILRT and the LLRT results for leaks isolated during the CILRT is needed to determine the "AS FOUND" overall leakag .'

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Both values are expected to be reported in the CILRT Technical Summary Repor The inspector independently calculated several mass values and leakage rate using raw data from the test. The results were in agreement with and verified the. accuracy of the licensee's leakage rate calculation . Facility Tours The inspector made several tours of the facility, including the control room, auxiliary building, and containment buildin During these tours the inspector observed operations and activities in progress, implementation of radiological controls, and the general condi-tion of safety-related equipment. In addition, the. inspector examined the containment system boundaries, component tagging, and instrumentation to support the CILRT. With the exception of the item described below no unacceptable conditions were identifie '

On June 18, while touring the containment building with licensee personnel, the inspector questioned the existence of a threaded cap installed on a two inch pipe at a penetration located on elevation 47 feet. The licensee later investigated this matter and determined that the particular penetration '

(#77) was one of four safety-related containment pressure sensing lines and should have been open, not capped. The licensee then checked the other three sensing lines and discovered the one at penetration #83 capped als After completing an investigation, the licensee was unable to identify who installed the caps; when they were installed; or with what authorizatio However, the licensee's investigation did conclude that the subject caps were installed during the recent outage.

l The resident inspector reviewed the licensee's analysis of records and logs which indicated that the isolation of penetrations 77 and 83 had occurred after the plant had been taken to COLD SHUTDOWN for refueling on April 15, 1982. Each penetration supplies transmitters for four safety signals (Saftey Injection Actuation, Containment Spray Actuation, Containment Isolation, and Reactor Protection Trip) within' Safety Divisions ZA and ZC l respectively. Divisions ZB and ZD were not affecte The signals and

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actuation systems are not required to be operable in the COLD SHUTDOWN and REFUELING modes in which the plant was placed for the duration of the i isolation, by the licensee's analysis.

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Voltage outputs from the various channel's trip systems (4 per trip system, 4 trip systems, 16 total for containment pressure) are logged on a shift basis. Deviations greater than 0.1 volts (0.375 psi) require the initiation of a maintenance action. The licensee plotted all four Safety Injection (ZA, ZB, ZC, and ZD) containment pressure signals for the period March 15 to April 15, 1982 (immediately prior tc the shutdown).

The licensee concluded and the inspector confirmed that numerous containment pressure transients between 0 and 1.1 psid tracked well among til channels, indicating that the penetrations had not been isolated during the previous operating cycle. The licensee further stated that upon removal of the caps in question (which were also sealed with teflon tape), the technician observed a positive pressure in the sensing line. This indicated that the pipe cap would hold pressure and therefore would not have allowed the sensors to respond as noted on the Control Room Operators logs. The inspector agreed with the licensee's conclusion that the penetrations had been isolated sometime during the refueling outag Calvert Cliffs Instruction (CCI) 200 F, " Maintenance Requests" is used to control maintenance and modification on safety related equipment and requires the use of a maintenance request (MR) form to authorize and document the performance of this work. By memorandum dated February'1, 1982, the Plant Superintendent reminded all personnel that all maintenance and modification work on safety related equipment must follow the adminis-trative controls established. This memorandum was part of the corrective actions taken for a violation in NRC Inspection Report 50-317/81-24; 50-313/81-23 which identified a lack of control for removal and assuring reinstallation of part of a safety related system. Similarly, the licensee management has been unable to determine who authorized, or why or when the two containment pressure sensing lines were isolated by addition of pipe caps. Further, no controls were noted which would have detected this and assured restoration of system operability prior to a return to operation Failure to adequately control activities affecting a safety related system violates 10 CFR 50, Appendix B, Criterion V, and FSAR Article IC.5, Revision 38, April 30, 1975, requirements for procedural controls over activities affecting quality. This a repeat violation (317/82-15-02).

6. Containment Integrity Verification During the CILRT a significant leak was discovered through the fuel transfer tube (penetration 42) into the spent fuel pool. The cause of this leak was determined to be a transfer tube drain valve located on the containment side of the penetration. This valve bypasses the fuel transfer tube blank flange which was previously recognized as the sole containment leakage limiting barrier for penetration 42. Drawing OM-58, revision 4, P & ID Spent Fuel Pool Cooling and Pool Fill and Drain System shows this

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drain valve, but without a specific identification number. The CILRT procedure valve line up designates this drain valve as 1-SFP-906 and verified it to be shut prior to the test. During the CILRT a test engineer examined this valve and reported that it was missing a handwheel and did not appear to be fully shut. He also installed a threaded pipe cap which -

stopped the leakage. Then the test was continued. The licensee explained and the inspector agreed that the normal configuration of this penetration should include this drain line valve shut and capped. This would conform with the general FSAR containment system penetration double barrier leakage protection scheme and satisfy the intent of 10 CFR 50, Appendix A, Criterion 54 and 56, Primary Containment Isolatio The inspector reviewed procedure STP 0.55-1, Revision 15, Containment Integrity Verification which is used to satisfy Technical Specification 4.6.1.1. It did not include the subject drain valve nor any part of the fuel transfer tube penetration 42. The inspector also reviewed procedure OI-24, Revision 11, Spent Fuel Pool Cooling System. This procedure was approved June 18, 1982 and did designate the subject fuel transfer tube drain valve (SFP-3) to be normally shut. However, the operating instructions did not specify the need for a cap to be installed. ' Previous revisions of the procedure did not recognize the drain valv Failure of the two identified procedures to recognize valve SFP-3 and specify the appropriate normal configuration to assure containment integrity represent an example of inadequate procedural control and a violation of TS 6.8.1 and Regulatory Guide 1.33. This failure contributed to a significant containment system leak discovered during the CILRT and is a violation (317/82-15-03).

7. Unresolved Items Items about which more information is required to determine acceptability are considered unresolve Paragraphs-2 and 4.5 contain unresolved item . Exit Interview The inspector met with licensee representatives (see detail 1 for attendees)

on June 22, 1982. The inspector summarized the scope and findings of the inspection at that tim With regard to the violation described in paragraph 5, the acting Plant Superintendent stated that their investigation of when and how the pressure sensing lines were isolated is ongoing and any documentation or information obtained would be brought to the Resident Inspector's attention.

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