IR 05000317/1990022
| ML20059N124 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/28/1990 |
| From: | Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059N120 | List: |
| References | |
| 50-317-90-22, 50-318-90-21, NUDOCS 9010100136 | |
| Download: ML20059N124 (5) | |
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U.S. NUCLEAR REGUL4'IORY COMMISSION REGION 1-Report No.
50 317/90 22; 50-318/90-21 License Nus.
DPR 53/DPR-69 Licensee:
Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203 Facility:
Calvert Cliffs Nuclear Power Plant,-
Units 1 and 2 L:, cation:
Lusby, Maryland i
Inspection Dates:
August 27,1990 to August 31,1990 Inspector:
Richard Laura, Resident inspector Nine Mile Point Nuclear Station Approved by:
W OO A
/Glenn Meyer, Chief Reactor Projects Sectio [n IB Date Division of Reactor Projects
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JDspection Summary:
This in.npection report documents the results of an announced regional initiative inspection in the area of Post Maintenance Testing.
Results:
No violations or unresolved items were identified. The PMT program was found to be comprehensive and well structured. An executive summary follows.
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I EXECUTIVE SUMMARY
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Th.: Post Maintenance Testing (PMT) Program was reviewed and assessed to be comprehensive and well structured with no programmatic weaknesses. The review consisted
of observation of testing in progress, review of recently completed maintenance order i
packages, and review of Calvert Cliffs Instruction-200M (CCI 200M), which delineates PMT
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and operability testing requirements. The PMT group is solely dedicated to PMT and is staffed with personnel with extensive operations experience. The group manages and
schedules PMT and thus minimizes the inspact on the operating shift organization. Two new -
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initiatives in the areas of post maintenance operability test tracking and trending of PMT
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results were in the process of being implemented and were indicative of being proactive.
The inspector identified an isolated example in which a test record in which the test did not fully meet the test acceptance critieria. Appropriate corrective actions were taken. In
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summary, the PMT program was found to be a good program and met the objectives of the l
Performance Improvement Program.-
l Quality assurance audits of PMT were reviewed and assessed to be acuptable, but the
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audits were compliance based rather than performance based. A quality assurance
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supervisor agreed and stated his plan to perform a more performance based audit of PMT.
in the near future.
The inspector observed an instance where a maintenance technician failed to follow station
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radiation protec: ion requirements when exiting a contaminated area in the Auxiliary Building.
This was reported to the radiological control supervisor, wha initiated a
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Radiological Control Report to investigate the incident.
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-l DETAILS
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1.
Background i
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This inspection was conducted to assess the quality and effectiveness of the Post Maintenance Test (PMT) program at Calvert Cliffs Nuclear Power Station. The area of PMTwas idenJ!ied in lection C.7 of the Calvert Cliffs Perfocaance Improvement i
Program as an area requiring improvement. A new PMT progrean was implemented -
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in June,1989. Selective elements of the NRC inspection plan for Performance
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Improvement Plan and Implementation Program were incorporated during this inspection.
The inspection consisted of a programmatic review and in-field observation of testmg.
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PMT r: gram The details of the PMT program are delineated in Calvert Cliffs Instruction 200M, Nuclear Maintenance Systems Appendix 200.30. A post maintenance / operability test document (PMTD) is generated following any maintenance performed under a maintenance order (MO). The PMTD contains the following infomation:
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Work description and recornmended PMT filled out t 90nsible
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maintenance group supervisor.
The actual PMT performed and results signed by the lead ulaintesance
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technician.
The recommended operability :est, actual operabihty test and results signed
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by the control room supervisor.
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The purpose of the PMT is to assure the original deficiency was corrected and no
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new deficiency has been introduced. The assignment of the recommended PMT tf
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the maintenance group planner is based on a PMT guide. The guide consisu of
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numerous modules which provide guidance in selecting the correct and approprive
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testing subsequent to the completion of maintenance tasks. The PMT is performed by maintenance technicians with the assistance of operations personnel, as needed
to operate equipment. After the PMT is completed, post maintenance operability testing is assigned and carried out by the control room supervisor. The operability testing is performed to ensure components and systems are tested to verify they will function satisfactorily following maintenance and to satis'y technical specifications operability requirements.
A PMT group exists whose charter is to review and manage the PMT program to minimize the impact on the operating shift organization. The group is composed 'of
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four individuals with previous operations experience. The head of the group is designated Post Maintenan';e Test Coordinator (PMTC). The PMTC must sign the i
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startup checklist prior to each mode change to acknowledge there are no outstanding post maintenance tests.
Two new program enhancements were in the process ofimplementation during this inspection. One improvement implemented a post maintenance operability test tracking system per Calvert Cliffs Instruction (CCI)-312 effective August 24,1990.
In essence, CCI 312 implements a tag system to flag to the operations staff when testing is required prior to taking credit that the system is operable. A second PMT program improvement is the trending of PMT results and notification of abnormal conditions to component and system engineers.
This enhancement is in the conceptual stage of development with a target implementation date of Maah,1991, These new initiatives demonstrate stathn management is proactive in developing the -
PMT program.
In summary, the PMT program was assessed to be comprehensive and well structured.
This assessment is based on:
differentiation between PMT and operability testing, dedicated PMTgroup with operations experience which minimizes PMT impact on the operations staff, the detailed PMT guide of high quality, being proactive in implementing further enhancements to the program, and the PMTC being accountable for outstanding testing by having to sign a startup checklist prior to each mode change.
3.
In Field Observations A sampling of PMTs and sperability tests was observed by the inspector. For each test, the scope of work perfarnad was compared to the PMTD to ensure proper
testing was selected and performei The following tests were observed:
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Operability Test: stroke test of stea'" generator feedwater isolation valves
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(HS4516 and HS4517) per STP-66-1.
PMT: stroke and functional test of the condenser ball collector valve in the
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Amertrap system.
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PMT: traveling screen 14A vibration test.
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PMT: #11 low pressure safety injection pump seal water temperature RTD
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modification.
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The inspector's assessment was the appropriate testing was selected and performed following the maintenance activities. During the performance of the PMT on the Amertrap ball collector valve, some confusion existed concerning how to properly ensure the valve flapper was properly seated. The PMT was not completed and required additional planning and operations support. The PMT specified in the PMTD was generic in nature as stated in the PMT guide. The inspector concluded that an increased level of PMT specificity could have resulted in less interpretation
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by maintenance technicians and that the maintenance planners should custc, min the PMT guide requirements for each job as much as possible to eliminate unnecessary confusion and to ensure the proper test is performed.
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'Ihe inspector reviewed approximately twenty completed maintenance order packages including the associated PMTDs. 'lhe proper PMT and operability tests were performed and documented. Only one minor discrepancy was noted on the PMTD for maintenance order 200050-769A.concerning the replacement of a non-safety.
related check valve in a sump system. The PMT acceptance criteria stated no i
leakage allowed from flanged connections. Leakage was noted on the check valve
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flange and the test was _ accepted as satisfactory.
This issue was raised to maintenance management who investigated the concern and directed the PMT to be
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reperformed. The responsible maintenance technician was counseled to ensure.
I better attention to detail. The inspector concluded that the error was isolated and that corrective actions were appropriate.
A contaminated area was entered to observe the PMT of the #11_ high pressure
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safety injection pump RTD modification. Upon exiting the area, a 30 second partial
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body frisk was required prior to exiting that level of the Auxiliary Building. The s
inspector observed the maintenance tecimician did not perform the required frisking
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and was exiting the area. This was pointed out to the technician, who then
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performed the frisking. This observation was reported to the radiological controls
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supervisor, who initiated a radiological controls report to investigate the mater. The
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investigation determined the technician forgot to perform the frisk, and radiation
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protection initiated corrective actions to prevent recurrence. The olanned corrective
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actions seemed appropriate to the inspector.
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4.
Quality Assurance Audits of PMT
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Audit 9010 issued in July,1990, performed an audit of the Corrective Maintenance
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Program. The inspector reviewed the portion pertaining to the PMT program and found it to be acceptable. It wr.s noted that only three elements of PMT program were reviewed during the audit and all were compliance based rather than
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performance based. Several other past audits in the area of PMTwere reviewed and found to be similar in nature. This concern was discussed with quality assurance l
supervisor who agreed with the inspector's concern anGtated he planned to perform a more performance based audit of the PMT program prior to restart.
5.
Exit Meeting
At the conclusion of the inspection a meeting was held with management to discuss
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the scope r.ad findings of this inspection. Based on the NRC Region I review of this report and discussions with Calvert Cliffs representatives, it was determined that this report does not contain Safeguards or 10 CFR 2.790 information.
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