IR 05000317/1983026
| ML20082E324 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/28/1983 |
| From: | Bissett P, Caphton D, Caphton D, Joffee D, Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20082E300 | List: |
| References | |
| 50-317-83-26, 50-318-83-26, NUDOCS 8311280145 | |
| Download: ML20082E324 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-317/83-26; 50-318/83-26 Docket Nos.
50-317; 50-318 License Nos. DPR-53; DPR-69 Category C
Licensee: Baltimore Gas and Electric Company P.O. Box 1475 Baltimore, Maryland 21203 Facility Name: Calvert Cliffs Nuclear Power Station, Unit 1 Inspection At: Lusby, Maryland Inspection Conducted: September 19-23, 1983
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Inspectors:
_ Bf sett, Reactor Engineer
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/G. M er,pactorEngineer
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a fee, NRR Ligensing Project
/ ddte Manager Approved by:
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D.'Capntc6, Chief, Management
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Programs Section, EPB Inspection Summary:
Inspection on September 19-26, 1983 (Combined Inspection Report 50-317/83-26 and 50-318/83-26 l
Area Inspected: Routine, unannounced inspection of safety-related Surveillance and its associated In-service Testing Program, Calibration Program, and Quality Assurance Program Description review.
The inspection involved 76 inspector hours onsite by two region-based inspectors and one NRR Licensing Project Manager.
Results:
i One violation was identified in one area (surveillance-failure to properly establish and implement a procedure, paragraph 2.4.1.2).
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8311280145 831109 PDR ADOCK 05000317 G
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DETAILS 1.
Persons Contacted Site: Lusby, Maryland E. Campo, Quality Control Surveillance Supervisor
- J. Carroll, General Supervisor, Operations
- R. Denton, General Supervisor Technical Services
- D. Latham, Principal Engineer,0perational Licensing & Safety J Lohr, Operations Surveillance Test Coordinator G. Pavis, Maintenance & Modifications Surveillance Test Coordinator J. Rivera, Shift Supervisor L. Russell, Plant Superintendent J. Sites, I&C Supervisor R. Sydnor, E&IC Surveillance Test Coordinator Corporate: Baltimore, Maryland
- A. Anuje, Supervisor, Internal Audit and Programs Unit
- R. Douglass, Manager, Quality Assurance (QA)
- J. Hoppa, Senior QA Auditor H. Shelley, Senior Engineer, Reliability and Availability Engineering L. Sundquist, Assistant to V.P.- Supply NRC
- R. Architzel, Senior Resident Inspector The inspectors also held discussions with and interviewed other licensee personnel during the inspection.
Note:
denotes those present at the site exit interview.
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denotes those present at the corporate exit interview.
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2.
Safety-Related Calibrations and Surveillance Tests 2.1 References / Requirements Technical Specifications, Section 6, " Administrative Controls"
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ANSI N18.7-1976, " Administrative Control and Quality Assurance for the Operational Phase of Nuclear Power Plants"
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Regulatory Guide 1.33-1978, " Quality Assurance Program Re-quirements"
ANSI N18.1-1971, " Selection & Training of Nuclear Power Plant
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Personnel"
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2.2 Administrative Controls The following procedural controls were reviewed to verify their conformance to the requirements listed in paragraph 2.1:
Calvert Cliffs Instruction (CCI).04F Surveillance Test Program,
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Change 13, September 8, 1983.
CCI-120C, Calibration Program for Measuring and Test Equipment,
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Change 1, October 5, 1981.
CCI-204D, Functional Test Procedure, Change 0, March 14, 1983.
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CCI-209B, Test Equipment Calibration Procedure, Change 0, July,
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1980.
CCI-211B, Preventive Maintenance Program, Change 1, June 16,
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1983.
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CCI-303C, Operations Preventive Maintenance Program, Change 1, September 8, 1983.
CCI-613B, Qualification of Test and Inspection Personnel, Change
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1, October 1, 1982.
Quality Assurance Procedure (QAP)-13, In-Service Inspection,
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January 23, 1981.
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QAP-16, Surveillance Testing, Revision 14, September 21, 1982.
QAP-17, Control and Calibration of Measuring and Test Equipment,
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Revision 15, September 21, 1982.
2.3 Review and Implementation
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2.3.1 On a sampling basis, the inspectors reviewed safety-related calibration and surveillance procedures and associated data sheets to verify that the program had been implemented in accordance with applicable procedures detailed in paragraph 2.1 and 2.2, above. The following areas of the program were re-viewcd and verified:
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A master schedule had been developed and is being main-tained for surveillance and surveillance calibration testing.
Responsibilities had been assigned for the performance of
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tests and that assigned test schedules were completed.
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Tests required by Technical Specifications were available and covered by properly approved procedures.
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Tests were performed within the required time frequencies
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specified by the Technical Specification.
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Test data results met acceptance criteria and, if not, appropriate corrective action was taken.
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Completed tests had been reviewed as required by procedure.
The following Surveillance Test Procedures (STP) were reviewed:
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STP 0-6-1, RPS Start-Up, Revision 6, November 13,1981.
Reviewed data for tests completed during June, July and August, 1983.
STP 0-62-1, Monthly Valve Position Verification, Revision
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15, July 13,1983.
Reviewed data for tests completed during July, August, and September,1983.
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STP 0-71-1, Staggered Test of "B" Train Components, Rev. 5, November 14, 1981.
Reviewed data for tests completed during April, May, and June, 1983.
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STP 0-89-0, Fire Suppression Weekly System Check, Revision 2, March 25, 1981.
Reviewed data for tests completed the previous five weeks.
STP 0-86-1, Boration Flow Path Temperature Determination,
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Revision 3, August 25, 1982. Reviewed data for tests completed the previous six weeks.
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STP M-150, Battery Pilot Cell Checks, Revision 3, January 14, 1981. Reviewed data for weekly tests performed during January, 1983.
STP M-350, Station Battery Quarterly Checks, Revision 7,
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January 14, 1983.
Reviewed data for quarterly tests completed in January, April, and July,1983. Also, re-viewed Maintenance Requests MR-E-82-442 and 443 associated with test performed during November, 1982.
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STP M-550, Battery Inspection and Service Test.
Reviewed data for two tests performed in November and one test pe formed in December, 1982.
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STP M-460-0, Sesmic Accelerometer Calibration.
Reviewed completed tests for April, 1983, and November, 1982.
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STP M-560, Sesmic Instruments Calibration.
Reviewed completed test for May, 1982.
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STP M-510-1, Reactor Protective System Calibration Check,
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Revision 9, April 23, 1982. Reviewed completed test for May, 1982.
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STP 0-65-2, Quarterly Value Operability Verification Test,
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Revision 23, March 2, 1983.. Verified operability of values SI-635, 636, 645, and 647 during July,1983.
STP 0-73-1, ESF Equipment Performance Test, Revision 18,
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June 15, 1983. Verified operability of #12 Low Pressure Safety Inspection Pump (September, 1983) and #13 Service Water Pump (March, 1983).
STP M-1-2, Steam Generator Snubber Reservoir Inspection,
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Revision 1, January 13, 1982.
Reviewed completed tests for l
June through September, 1983.
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STP M-2-2, Pressurizer Safety Valves, Revision 1, April 14,
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1982.
Reviewed completed tests for January,1981 and November, 1962.
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2.3.2 The inspectors witnessed the performance of STP 0-7-1,
" Engineered Safety Features Logic and Performance Test" and STP 0-52, " Auxiliary Feedwater System" surveillance tests to verify that the following was accomplished:
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Test procedure was available and used.
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Test equipment required by the procedure was calibrated.
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Ter.t prerequisites were met.
System restoration was correct.
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i Details of the observed surveillance tests are discussed in paragraph 2.4.
l 2.3.3 During the review of completed surveillances, the inspectors randomly selected four individuals (two instrument control technicians and two electrical control technicians), who had participated in the performance of several surveillances. The inspectors reviewed the training records and qualification l
certificates of these individuals to insure that they were i
qualified to perform the surveillances that had been reviewed by the inspectors.
2.3.4 Also, during the review of completed surveillances, test equip-l i
ment (Stopwatch #10867, Heise Gauge #17494) used during the performance of surveillances was checked against their respect-ive calibration log sheets. Also, records were reviewed to verify that the test equipment used as the primary standard for the in plant calibration of the Heise Gauge had been calibrated i
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to standards traceable to the National Bureau of Standards.
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2.3.5 An inspection was conducted, on a sampling basis, of the imple-mentation of the licensee's In-Service Testing Program (IST) for Pumps and Valves. The IST Program implementation was inspected fer conformance to the licensee's current program submittal, Sections 3 and 4 of the Technical Specifications, and the appropriate plant administrative requirements.
In-Service Testing of Pumps and Valves is accomplished through incorporation into the Surveillance Testing Program. Those pumps and valves, and associated test procedures that were randomly selected and reviewed are listed in paragraph 2.3.
L 2.4 Findings 2.4.1. STP 0-7-1, " Engineered Safety Features Logic and Performance Test" 2.4.1.1 Procedure Review STP 0-7-1, Revision 27 satisfies the requirements of Technical Specification 4.3.2.1.1, " Engineered Safety Feature Actuation System Instrumentation" for monthly testing of the Engineered Safety Features (ESF) logic.
Prior to reviewing performance of the STP, the procedure was reviewed and compared against material in the Final Safety Analysis Report (FSAR),
Certain control logic is exempt from monthiy testing as noted in Technical Speci-fications.
The following items were noted:
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FSAR Section 7.3.2.2 indicates that Safety Injection (SI)-659 (minimum flow valve) closes on RAS A-1.
The STP indicates that SI-659 should be verified open.
This inconsistency is due to a lockout feature which is required by Technical Specifications.
FSAR Section 7.3.2.2 indicates that Containment Valve
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(CV)-5210 opens on Safety Injection Actuation Signal (SIAS) from subchannels 7 and 9.
The STP does not verify this valve open for SIAS subchannels B-7 or
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A-7.
This is apparently an error in the FSAR in that the correct actuation channel is only subchannel 9.
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FSAR Section 7.3.2.2 states that the Containment Isolation Signal (CIS) subchannel 3 opens Penetration Room Filter #11 Damper Isolation Valve,1-SV-5285.
The STP (Step 164) verifies that the #11 filter isolation dampers HVAC-5285 and 5286 open. These dampers are both actuated by solenoid valve #1-SV-5285 (refer to FSAR Figure 9-20A). The FSAR description i
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should be revised to accurately describe the com-ponents which actuate on the CIS. A similar situation exists for Penetration Room Filters #12, 21, and 22.
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The STP indicates the Pressurizer heater breaker 52-1127 opens on SIAS subchannel A-4. The FSAR does not reference this automatic action. The same sit-uation exists for Pressurizer heater breaker ;2-1427.
Correction of these FSAR inconsistencies is unresolved (317/83-26-01).
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STP 0-7-1 is not consistent in requiring a " sign-off" when equipment is returned to service (e.g., valves realigned, pumps stopped, etc.) after testing.
This inconsistency was also noted during the review of other STFs.
STP-0-7-1 also does not consistc itly verify the status of equipment prior to testing (e.g.,
equipment that is automatically started on an Engi-neered Safety Features Actuation System (ESFAS) signal should always be verified to be stopped prior to testing.) The licensee agreed that this area of concern needed further evaluation and stated that a check-off system or a more detailed sign-off system might be instituted. This item will-be followed in a subsequent NRC:RI Inspection (317/83-26-02).
2.4.1.2 Conduct of Testing The conduct of STP 0-7-1 at Calvert Cliffs Unit I was verified by direct observation during the mid-shift on September 19, 1983. The STP was conducted by Control
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due to a manual reactor trip. Testing per STP 0-7-1 was restarted on September 20, 1983.
I During conduct of the STP on September 20, it was noted that the Control Room Operator (CRO) missed step
- 160. This step requires that #11 Spent Fuel Cooler Service Water Inlet Valve (SRW-1597) be opened fol-
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lowing testing of Containment Spray Actuation Sigr al (CSAS) B-3. On initial questioning, the CR0 indicated that he had opened the valve. Direct observation cv the inspector indicated that the valve was closed.
The CR0 promptly opened the valve upon being informed that it was closed. The inspector noted that this step does not require a " sign-off."
Technical Specifica. ion 6.8.1 requires that written procedures shall be established, implemented and l
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maintained covering (a) applicable procedures recom-mended in Appendix A of Regulatory Guide 1.33, Re-vision 2 (which includes Operating Instructions for Service Water Systems) and (b) Surveillance and Test activities of safety-related equipment. A review of Operating Instruction (0I)-15, Revision 14, June 21, 1982, " Service Water System" indicated that the service water side of the Spent Fuel Pool Coolers should have their outlet valves (SRW-1596 and SRW-1598) open and their inlet valves (SRW-1597 and SRW-1599) "as desired," depending on the operational status of the coolers. STP 0-7-1 and 01-15 are inconsistent in that, following testing of CSAS A-3, the STP places SRW-1596 in the "as desired position."
Also, the STP places SRW-1597 in the open position l
following testing of CSAS B-3.
Thus, the STP does not
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restore the subject valves to the position specified in 01-15. This represents an error in the establish-ment of the procedure (s).
Failure to open service water outlet valve SRW-1597 to the Spent Fuel Pool Cooler as specified in STP 0-7-1 represents an error in implementation of the procedure (s).
As a result of this error, a redundant method of overpressure protection (in addition to an installed relief valve) for the isolated #11 Spent Fuel Pool Cooler was not provided. This was the intent of the STP and OI valving arrangements.
Failure to properly establish and implement STP 0-7-1 and/or 01-15 is a violation (317/83-26-03).
During the performance of the STP, sound judgment and training was shown in the following and should be considered for in-l clusion in STP 0-7-1:
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Prior to lining up a pump to a particular bus, the l
pump was placed in " pull-to-lock." This prevents a disconnect from being opened on a running pump which can be dangerous to personnel.
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When diesel generators were shutdown after testing,
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they were tripped at one-minute intervals. This prevents two diesel generators from being inoperable during the same 60-second interval due to the restart
" time out" on the diesel generators.
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2.4.2. STP 0-52, " Auxiliary Feedwater System" 2.4.2.1 Procedure Review The purpose of STP 0-52 is to demonstrate operability of the Auxiliary Feedwater (AFW) System and meet the Technical Specification requirement (4.7.1.2a.1 and 4.7.1.2a.2) for monthly measurement of Total Dynamic Head (TDH) of each AFW pump. Prior to observing per-formance of STP 0-52, the procedure was reviewed for content. The following conclusions were reached:
a. Execution of the procedure meets the requirements of Technical Specification 4.7.1.2a.1 and 4.7.1.2a.2 for measurement of Auxiliary Feedwater System pump TDH.
b. STP 0-52 complies with Technical Specification 3.7.1.2 in that it requires (a) an operator (dedicated) stationed at the AFW local control center, in direct communication with the Control Room, when a pump or flow train is made in-operable for purposes of testing, and (b) in-dependent verification of AFW lineup, by an independent operatur.
2.4.2.2 Conduct of Testing The performance of STP 0-52 for Calvert Cliffs, Unit 2 was reviewed on September 22, 1983. The test was performed according to STP 0-52 until failure of MS-4070-CV (Turbine Steam Supply) terminated the test.
The test was completed following repair of MS-4070-CV.
During performance of the test, it was noted that a
" locked valve deviation" sheet was being incorrectly maintained by an operator who was located in the Unit 2 Auxiliary Feedwater Pump Room.
Following a review of this situation with the Shift Supervisor, it was determined that a correctly maintained " locked valve deviation" sheet was being properly maintained in the Control Room.
A review of CCI 300F, Section 8, " Locked Valve Devia-tion Sheet," indicated that this procedure does not clearly assign responsibility for control of locked valves at the location of the test (in this case, at the Auxiliary Feedwater Pump Room) or in the Control
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Since at least two locked valve deviation sheets were being maintained during the September 22, 1983 conduct of STP 0-52, it was clear that some members of the Calvert Cliffs operations staff were unclear on this point. Clarification of locked valve deviation policy at Calvert Cliffs will be followed in a subsequent NRC:RI inspection (317/83-26-04).
3.
Quality As:urance (QA)
3.1 Quality Control (QC) Surveillance The inspector interviewed the QC Surveillance Supervisor to
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ascertain the involvement and interface between QC and those departments that perform safety-related surveillances. The inspector was informed that all Surveillance Test Coordinators forward to him monthly surveillance schedules, which provide him the opportunity to select certain surveillances that QC will witness, either in its entirety or designated bold points. QC also maintains 100% coverage of those surveillances with asso-ciated maintenance requests.
3.2 Quality Asssurance Program Description In accordance with 10 CFR 50.54(a), the Quality Assurance (QA)
Program Description for Calvert Cliffs, Units 1&2, was submitted by a letter dated June 17, 1983.
In a letter dated August 18, 1983, Region I identified the need for additional information to complete the review of the QA Program Description.
In a separate meeting held September 23, 1983, the following supporting information to the QA Program Description was re-viewed:
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Licensee letter to NRC, August 5, 1981, concerning quali-fication of inspection, examination, testing, and audit personnel; and NRC response letter, July 23, 1982.
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Licensee letter to NRC, February 11, 1983, concerning storage of QA records; and NRC response letter, April 22, 1983.
Procurement and Storage Manual, Section 11, Packaging,
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Handling and Storage.
Based on discussions with the licensee, the inspector stated that quality assurance practices in the following areas appear to be acceptable, but that clarifications to the QA Program Description are needed to properly reflect existing practice.
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Section 182, page 1B-8: A commitment to Regulatory Guide 1.58 has been omitted.
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Section 1B7, page 1B-21: The description of conditional
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release of inspected items should indicate that a non-conformance is written up to track completion of the editorial release.
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Table 1B-1, ANSI.N45.2.2-1972, Item 3, 4, and 5: The exceptions to ANSI N45.2.2-1972 should be clarified to specifically identify those stituations in which the exceptions apply.
Table 18-1, ANSI N45.2.2-1972, Item 6: The exceptions for
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packaging during storage should be clarified to show that all storage will be under Level B conditions.
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Table 18-1, ANSI N45.2.9-1976, Item 2: The exception concerning ventilating ducts and electrical pipes entering the records vault should be clarified to show these pipes or ducts will be designed to be compatible with the vault's fire rating.
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Table 18-1, ANSI N45.2.23-1978, Section 2.1: The re-quirements for technical experience credits should be clarified to state that time credited under Section 1.4 cannot be used in Section 2.1.
The licensee agreed to resolve the above items and to submit the next revision of the QA Program Description with the resolutions to Region I for approval (317/83-26-05; 318/83-26-05).
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Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations, or items of non-compliance. One unrcsolved item was identified during this inspection and is detailed in Paragraph 2.4.1.1.
5.
Management Meetings Licensee Management was informed of the scope and purpose of the in-spection at an entrance interview conducted on September 19, 1983. The findings of the inspection were periodically discussed with licensee representatives during the course of the inspection. An exit interview was conducted both at the site and corporate office on September 23, 1983 (see Paragraph I for attendees), at which time the findings of the in-spection were presented.
At no time during this inspection was written material provided to the licensee by the inspectors.
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