IR 05000317/1990018
| ML20059E209 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/20/1990 |
| From: | Baunack W, Bessette D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059E195 | List: |
| References | |
| 50-317-90-18, 50-318-90-17, NUDOCS 9009100090 | |
| Download: ML20059E209 (6) | |
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U. S.; NUCLEAR REGULATORY COMMISSIO4-
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REGION I
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N Report Nos. '50-317/90-18 50-318/90-17
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Docket Nos; 50-317
50-313-License Noss.
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-DPR 69
t JLicensee: Baltimore' Gas and Electric-Company MD Rts. 2 & 4', P.O. Box 1535 Lusby, Marylandi 20657 i
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'f-Facility Name: CalverttCliffs-
LInspection.At: lLusby,' Maryland?
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I_nspection Conducted:_ July 16-20, 1990 y
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Inspectors:
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H.- Baunack, Sr,-Reactor Engr.
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-Operational. Programs-'Section, 08, DRS
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-Approved by:
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.D.,Bessette,-Chief Operational. Programs
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.Section,.0perations Branch, DRS
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tInspection Summary:
Routine Unannounced Inspection of Licensee's Control of; Surveillance Testing 1 Report Nos.150-317/90-18-and 50-318/90-17).
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, Areas: Inspected: An inspection was conducted-to review the licensee's program for,the control of surveillance testing.
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i Results:
N'o' violations o'r1 deviations were identified. The licensee's Performance
fImprovement Program and its' Procedure Upgrade Program are being developed and.
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implemented ~to improve conduct of the Surveillance Test Program. Significant
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work: remains to:be done,Lwith overall-implementation scheduled to be-completed j-by December, 1992
'In;the interim an acceptable program is being conducted.
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PDR ADOCK 050003176 W
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DETAILS 1.0 Persons Contacted 1.1-Baltimore-Gas and Electric Company D. Buffington,-Functional Surveillance Test Coordinator, Fire Protection
=T. Camilleri, Nuclear Maintenance, Superintendent-C. Cruse, Nuclear' Engineering Services', Manager
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R. Denton', Plant Manager
G. Detter,-Director, Nuclear Regulatory Matters
'L. Larragoite, Licensing Work Group Leader
D. Latham, General Supervisor,- Procedure Upgrade Project M. Milbradt, Compliance Engineer
R.- Niedzielski, Procedure Development
B. Pace, Senior Reactor Operator
W. Rummel, Performance Engineering, Engineering Analyst J. Schoolcraft, Procedure Analyst
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J.' Thorp, Assistant General Superintendent, Operations Support
lL. Weckbauch, General Supervisor, Electric and Controls
- - S. Welp, Performance Engineering, Principal Engineer
- . L. Wenger, Performance Engineering, Principal Engineer 1~.2 U.S. Nuclear Regulatory Commission L. 'icholson, Senior Resident Inspector
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Denotes those attending exit meeting.
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.The inspector also held discussions with other administrative and technical personnel during the_ inspection.
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.2.0 Purpose.
This inspection was conducted to determine the status of the licensee's program for the control and' implementation of-the Surveillance Test
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12.1;' Background i-The Surveillance Test Program (STP) had been determined to be deficient"in
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certain areas during'Special Team Inspection 50-317/89-200.
Improvements l
are'being made as part of the. Performance Improvement-Program (PIP) and
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Procedure Upgrade Program (PUP).
PIP and PUP'are expected to be completed
by December, 1992.
This inspection reviewed the STP as it currently
exists.
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2.2 Surveill'nce Test Program Control
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The STP is controlled by Calvert Cliff s Instruction (CCI) 104J, Surveillance
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Test Program.~ This procedure establishes requirements for most testing
required by Technical Specifications.
Certain nuclear engineering, post-
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startup testing, chemistry, and surveillances performed at intervals of
less than 7 days are not included in CCI 104J.
Prior to August, 1989, STP-
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The C I 104J. established a strong centrally controlled STP.
Certain other changest intended to further strengthen the program, are being considered.
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The CCI-104J procedure specifies responsibi.lities for all. departments,
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in the STP.
In a major change to the previous program which divided'
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responsib.lities among various groups, the current program established a Site Surveillance Test Program Manager (9eTPM), who has the responsibility and authority to. administer the STP.
Reporting to the SSTPM are Functional Surveillance Test Coordinators (FSTC),' who administer the surveillance tests assigned to:them.
Their responsibilities include maintenance,of-Surveilla~nce Test Procedures for their assigned area including.ensu' ring that:' all surveillance requirements are met; tests are properly scheduled; i
e test results are reviewed and trended where required; and deviations from acceptance criteria are reviewed.
Currently, seven'FSTC have been assigned:
Operations, Electric and Control, Mechanical, Fire Protection, Inservice
' Inspection, Integrated Leak Rate Testing, and Snubber.
The CCI 104J provides instructions for preparation, review, and approval of surveillance test procedures,'and for identifying all new technical
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specification requirements. The procedure provides for.a double check of i-the schedu~1e for surveillance testing. The ' qualifications of personnel performing the testing are also addressed.
Disposition of malfunctioning and' out of. specification conditions is specified, as well as review requirements for-completed tests and record keeping.
Inservice testing of pumps and valves is currently being administered by the Operations FSTC.
Certain changes.to this program are planned and an early draft procedure CCI-164,Section XI Pump and Valve Program has been
. prepared.
.The inspector's. review of CCI-104J noted a number of questions such as:
failure to clearly identify the assigned FSTC; interface between STP procedures other procedures in the areas of licensing and post-maintenance l
testing;.use of certain forms prior to their being approved; promptness of (
completed test reviews; and identification of data required to be trended.
A newly revised CCI-104K has been approved and will be issued shortly.
This revision resolved many of the inspector's questions.
Other issues, such-as data trending, will be included in an overall condition monitoring system which is being considered.
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It appears that administration of; the STP has-improv,ed-greatly. since it August, 1989. Many changes were made and additional changes are planned.-
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.A positive aspect of the current program, although not required by
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procedure,-is the monthly meetings conducted among the SSTPM, the FSTCs,
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and other management personnel, to discuss quality and' control of the STP.
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In-summary, the STP has improved, additional changes 'are being implemented,
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This makes final assessment of the program y
premature.
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2.3 Surveillance Test Procedures
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yP Procedural problems were identified previously in Special Team Inspection l
V 50-317/89-200.
These included format inconsister.:ies between various groups,
inconsistencies in use of signoffs, and unclear acceptance criteria.
To.
- eliminate these deficiencies, a Procedure Update Program (PUP) was= initiated to upgrade all ~ Surveillance Test Procedures (STP) to a common format.
PUP i
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is scheduled to be completed by December, 1992.
Review of a recently
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rewritten procedure shows the new procedure clearly _ identifies the purpose, applicability / scope, references, prerequisites, precautions, step by step performance,' and acceptance criteria. The new procedures also prov.ide for
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comments-from the procedure users for improvements.
Selected completed procedures identified in the attachment to this report-i were' reviewed. Most were in the older formats and still contained'the
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.previously identified weaknesses.
In general, only minor deficiencies i
were identi fied.
Several surveillance tests were-not listed in the implementing surveillance test matrix of the Technical Specifications.
em Also, significant numbers of procedure changes were evident.
The licensee
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indicated some changes resulted from increased emphasis on procedure-
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The number of procedural changes as.well as the age of some a
changes was discussed with the licensee, who indicated that changes are j
E not being incorporated into procedure revisions as quickly as would be
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desired due to emphasis.on the PUP, J
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. Surveillance Test Procedure implementation was discussed with procedure
users, who expressed two concerns: '(1) the difficulty in reading procedures W
which had extensive pen and ink changes; and (2) too many changes to a
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procedure before a revision is made.
Procedures M-510 (RPS Calibration
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. Check) with seven changes and M-210A, (Reactor Protection System runctional yf Test (Shutdown)) with eleven changes were identified specifically.
These
j concerns were discussed with the licensee, who noted that procedure changes s
f, can'be incorporated into a procedure by either word processing or pen and i,
ink changes.
The licensee believes that the current procedural legibility K,*
controls for pen and ink changes, the requirement for no more than five
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M@9 such changes before a procedure revis, ion is required, and the
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pre-implementation review which has sent procedures-to word processing prior to use, are adequate to assure procedure legibility.
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Nevertheless,'a revision to CCI-101, Calvert Cliffs Implementing Procedure.
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!jf Development and Control, is to be issued shortly to further clarify _
p proceduro change requirements.
The concern that_too many changes are t IL permitted before a procedure is revised will,be addressed as Problem
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Es-Report 1566, which will evaluate and resolve the matter.
Since all
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Surveillance Test Procedures are scheduled to se revised,-all changes to
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procedures will_be incorporated at that time.
The licensee's actions
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wh In summary, the licensee initiated a PUP to revise all STP station N
procedures. GivenLits limited implementation to date, the program g
effectiveness cannot yet be evaluated.
NJ 2.4: Calibration of Safety-Related Instrumentation Not Identified in the
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' Technical Specifications
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The licensee's program for scheduling and calibrating instrumentation-not
identified in-the Technical Specifications was part of the preventive yfL,
maintenance program; however, deficiencies were identified during the
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my Special Team Inspection in program implementation.
In response, the-(
111censee is developing-a calibration index of components and has prepared f
' draft procedure CCI-229, Periodic Calibration of Plant Instrumentation.
'Y No further inspection of:this area was performed.
2,5 ESurveillance Test Program Evaluation a
,o The inspector: reviewed the licensee's effectiveness verification of its-f
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l STP. 'An-audit was performed from April 2 -to June 7,- 1990, to verify.
implementation and effectiveness of the STP, The audit appeared to be i
n'y thorough, and resulted in nine findings and two: recommendations. Audit-
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findings indicated improvements have been made, but some areas require W
further improvements. The licensee believed the number of findings to be L.
-too many and will increase its attention to this area.
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. Exit Meeting d
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W The findings of the inspection were discussed periodically with represen -
tatives of the licensee during the course of the inspection. An exit;
meeting was conducted on July 20,.1990, at which time the findings of the'
inspector.were presented, l
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At no time during the inspection did the inspector provide written mater-p ial to the licensee nor did the licensee indicate that areas covered by
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the inspection contained proprietary information.
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Attachment
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Procedures' Reviewed
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STP-0-73A-1, Saltwater Pump Performance Test.
i STP-0-65-1, Quarterly Valve Operability Verification Operating.
.STP-0-731-1, HPSI' Pump No. 11/12/13 Operability and Full Stroke Test.cf
. HPSI Minimum Flow Return Check Valves.
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STP-0-73K-1, Containment Spray Pump No.11/12 Operab'111ty and Full Stroke:
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Test of Minimum Flow Return Check Valves, h3 1-SI-334/1-SI-344 (Modes 1 thru 6).
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STP-0-73J-1, LPSI Pump No. 11/12 Operability and Full Stroke Test'of LPSI Minimum Flow Return Check Valves 1-S1-448/1-S1-451 (Modes 1 'thru 6).
STP-M-690-1, Hose Station Inspection - Shutdown-
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STP-M-539-1, PORV/ Safety Valve Acoustic' Monitor Calibration.
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STP-M-672-1, Pressurizer Relief Valve (ERV) Channel Functional Test.
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