IR 05000317/1990023
| ML20058A694 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/15/1990 |
| From: | Roxanne Summers NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058A686 | List: |
| References | |
| 50-317-90-23, 50-318-90-23, NUDOCS 9010290088 | |
| Download: ML20058A694 (31) | |
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. o , . U.S. NUCLEAR REGULATORY COMMISSION REGION 1 50-317/90-23 Report Nos.: 50-318/90-23 DPR-53 " License Nos.: DPR-69 Licenses: Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203 Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, Maryland Ihspection conducted: August 12, 1990, to September 15, 1990 Inspectors: Larry E. Nicholson, Senior Resident Inspector Allen G. Howe, Resident Inspector Tae J. Kim, Resident Inspector Henry K. Lathrop, Resident Inspector. Hope Creek s Vicur M. McCree Operations Engineer William Oliveira, Reactor Engineer Approved by: d~h.b e uA_ lo ' 15" 9o lobert J." Summers, Acting Chief.
' Datr Reactor Projects Section No. IA-hpettionSummary: e 'This inspection report d>caments routine and reactive inspections during day and backshif t-hours of st,w on activities including: plant operations; radio-logical protection; surveillance and maintenance; emergency prepaiedness; security; engineering and technical support; and safety assessment / quality _ verification.
, ' . _Re sults: ! [ A'n unresolved item was identified regahding inadequate controls for: fire doors ~ - ~(Section 8.5)' _An Executive Summary follows.
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_ . ,. ,. .. o j EXECUTIVE SUMMARY f Inspection Report Nos. 50-317/90-23 and 50-318/90-23 i Plant Operations: (Modules 71707, 93702) Several plant events during this period were caused by inadequate control of activities and inattention to detail.
These events included the loss of shutdown cooling, an incorrect equipment lineup and an inadvertent start of a reactor coolant pump. This last event indicated weakness in the ability to adequately assess and communicate the full imp 1' cations of defective equipment.
Immediate response by control room operators to these events were appropriate and timely.
Radiological Protection: (Module 71707) The licensee implemented its radio-Togical event plan in response to an unexpected change in radiation conditions in a hallway of the Auxiliary Building.
Inspection of this event found that licensee response was adequate.
Routine reviews of radiological protection found no adverse conditions.
Surveillance and Maintenance: (Modules 61726, 62703) Routine inspections of Tacility maintenance and surveillance activities found that these activities were being properly implemented.
Eme.r_gency preparedness: (Module 71707) Routine review in this area identified no noteworthy findings.
Secur jit : (Module 71707) Licensee response to a loss of power to the second- ~~ ary alarm station and the subsequent failure of the security diesel generator were appropriate.
Other routine review in this area identified no noteworthy findings.
.Em ineering_and Technical Support: (Modules 71707, 90712, 92700) The licen-T see s engineering and technical support organizations addressed several issues that had a = direct impact-on the readiness for unit 1 startup. Good effort was a observed in developing-a performance monitoring program for the service water heat lexchangers. The inspectors noted appropriate application of resources to these issues and determined. that safety issues t were adequately addressed.
! . Safety, Assessment / Quality Verification: (Modules 71707, 30703) The Startup heview Eard was found to be effective in focusing the station staff on resolu- . p ,. tion;of safety significant. issues prior to restart.
> A large number of identified drawing deficiencies, repeat problems on fire door controls,.and the failure to fully assess the procedure: inadequacies pertaining L to abnormal system alignments indicate a weakness regarding the timely develop- ' . ment ~and implementation of corrective actions.
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- The' licensee's Procedure Upgrade Program was reviewed a'nd found acceptable.
- . -This review resolves concern ST1-30 which was addressed in the NRC special team -
inspection 50-317/09-200 and 50-318/89-200.
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[ DETAILS 1.
lummaryofFacilityActivities L Unit I remained in cold shutdown for the duration of tne inspection period in a planned maintenance outage. Preparations were un m ay for a restart [ as the period ended.
Unit 2 remained defueled for the extended cycle 8 refueling outage with the fuel in the spent fuel pool.
Major activities included the steam" ~ generator thermal sleeve inspection and repair.
[ On August 27, 1990 Commissioner James R. Curtiss toured the site and met with several members of-the licensee staff. Mr. M. Wayne Hodges Director for NRC Region 1 Division of Reac'.o r safety, Mr. Curtis J. Cowgill, Section Chief _ for NRC Region I t1 vision of Reactor Projects, and / Iv Mr. David C. Trimble, NRC Technica# Assistant for the Commissioner, L accompanied Commissioner Curtiss on nis tour.
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Plant Operations 2,1_ O erational Safety Verification J The inspectors observed plant operation and verified that' the $ facility was operated safely and in accordance with licensee proced-ures and regulatory requirements.
Regular tours were conducted of the following plant areas: . s V.
-- control room- -- security access point L - ' primary-auxiliary building - protected area fence
-- radiological control point -- intake structure 4, -- electrical switchgear rooms. -- diesel generator rooms , p -- auxiliary.feedwater pump rooms -- turbine building g e .. - f' . In addition', on. September 12, the inspectors performed a-comprehen-V , sive tour of the Unit 1_ containment to assess readiness for restart, pJ ' With the exception'of some minor discrepancies and work that was or-going,: the. containment waso determined to be in-good overall condi- - g, tion.- Equipment was properly stored and the containment sumps and g b' screens -were, in good condition and. free - of : debris.
Inspectors ' observed that-the licensee implemented coordinated and disciplined-L' activities to ensure a thor _ough containment closeout._ ~ ' > {
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Control room instruments and plant computer indications were observed ! for correlation between channels and for conformance with technical , specification (TS) requirements.
Operability of engineered safety
features, other safety related systems and onsite and of fsite power ' , sources was verified.
The inspectors observed various alarm condi-
tions and confirmed that operator response was in accordance with i [ plant operating procedures.
Routine operations surveillance testing was also observed.
Compliance with TS and implementation of appro-
, priate action statements for equipment out of service was inspected.
! Plant radiation monitoring system indications and plant stack traces were reviewed for unexpected changer. Logs and records were reviewed i to determine if entries were accurate end identified equipment status e or deficiencies.
These records incluGd operating logs, turnover
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sheets, system safety tags, temporary moo fications, and the jumper I and lif ted lead book.
Plant housekeeping controls were monitored, t including control and storage of flammable material and other poten-f tial safety hazards.
The inspector also examined the condition of i verious fire protection, meteorological, and seismic monitoring sys-l 'tems.
Control room and shif t manning were compared to regulatory .
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requirements and portions of shift turnovers were ebserved.
The
b# inspectors found that control room secess was properly controlled and . 'that a professionai :tmosphere was maintained.
, , i L In addition :to normal utility working hours, the review of plant J g operations was routinely conducted during evening shifts and weekend + and midnight shifts.
Extended coverage was provided for 18 hours' during ' backshif ts and 27 hours during deep backshifts.
Operators ' , were alert and displayed no signs of inattention to duty or fatigue.
l r 2.2 Followup of Events Occurring During Inspection Period j .-
. . During the inspection period, the inspectors provided onsite' coverage
and followup of unplanned events.. Plant parameters, performance of
safety ' systems, and licensee actions were reviewed.- The inspectors ' ' confirmed that the required notifications were made to'the NRC.
Dur-
' g*. " ing event followup, theJinspector reviewed the' corresponding-CCI-118N
, (Calvert Cliffs Instruction,; " Nuclear Operations Section Initiated , , h,' Reporting : Requirements")' documentation, including the event details, ' root cause analysis, and corrective actions taken to prevent recur-
E rence. The following events were reviewed.- L i bNa , h i y '
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Loss of Security Power
On August 11, 1990, the licensee notified the NRC Operations i Center via ENS at 6:45 a.m., of a loss of power to the security
systems at the Calvert Cliffs 1 and 2 Nuclear Power Station. At 5:12 a.m., a duct heating unit for the Security Processing Facility shorted and caused the Main Power Feed, Bus #22 to trip on a ground fault.
The security diesel generator auto-matica11y picked up the security systems' load and ran for about 1/2 hour when it ran out of fuel at 5:47 a.m.
Compensatory measures were immediately implemented and the level of security was not degraded.
Power was restored to all affected systems at 7:02 a.m.
Licensee investigation for the failure of the diesel generator found air in the engine fuel line. The origin of the air may have been a stuck or sluggish float switch on the fuel oil day ! tank.
This may have caused delay in actuation of the fuel oil transfer pump allowing level to go below the inlet to the fuel L line. Further testing of the diesel generator has not been able ' to reproduce this failure. Initial corrective action was initi-l' ated to increase the weekly test run time to one hour to ensure that the float switch and fuel transfer pump are cycled.
The licensee is implementing additional corrective action to perform periodic maintenance on - the float switch and transfer. pump.
During ahe initial troubleshooting effort with_ the diesel gen-erator, the control switch for the. generator exciter breater was.
,, inexplicably found open...The switch is now routinely verified.
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L to be in the proper position (closed) several. times a day.
" Additional corrective actions'to protect the Security Processing Facility power supply lfrom future f ailures are under considera-tion. The inspector assessed that effective short term measures
- have been taken to ensure security diesel generator reliability.'
. Proposed long, term actions to further improve.the reliability of L the security diesel generator and to protect the power supply'to the Security Processing Facility appear to be appropriate.
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' Inoperable Emergency Diesel Generators p ' At 11:45 p.m., August 13, 1990, the ' licensee ' discovered ; that both No. _11 and No'..-12' Emergency Diesel Generators (EDG's) were inadvertently out of service for a ' period of three hours u, . earlier :in the - day..The No. 12 EDG was made < inoperable at W 12:20- p.m. when oper6 tors,' who were aligning the salt water (SW) m , b' (x Il 4' bi N1 , , www
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system in an infrequently used configuration to support mainten-
ance activities, failed to align the power supply for the No. 13 SW pump to the electrical bus powered by No 12 EDG, Thus the ! No.12 EDG did not have a source of coolirs nater powered from its associated emergency bus. No.11 EDG wasaut of service for other maintenance at the time but was teste:: satisfactorily and Fl returned to service at 3:27 p.m.
' The licensee initiated a CCl-118 report and a problem report.
' ' The General Supervisor, Nuclear Operations,. requested a Human Performance Evaluation System (HPES) review of the event since the potential for personnel error existed and the reasons for t L; the problem were not clear.
The Plant Operations Safety Review ' Committee (POSRC) chairman also initiated action for the commit- )- tee to review the event.
Additionally, the procedure section that caused this event was deleted from the SW procedure.
Licensee review of the event determined that the event was not reportable since no technical specification action statements , were exceeded during the time both EDG's were inoperable and offsite power was continuously available.. Additional licensee investigation revealed the following:- , ~ ' 1.
The procedure for th%5 evolution contained an initial con-dition (step 4), that required operators to realign the 13 L SW pump power supply.
In addition to_ step 4, operators discussed the procedure withL the control room supervisor p and also reviewed an August 7-1990, GS-N0 Note and ' Instruction (Night Order) which further described the-electrical lineup.
Subsequent licensee review concluded k that -the procedure wording was unclear, the GS-NO Note was-L misinterpreted, and-the operators were not' completely-L informed about the intent of. the procedure. This procedure-was a new section,in the SW operating instruc_ tion and had.
, , not' been :previously used.-. A contributing f actor.was that theref was no pre-job briefing. - Also some of the initial
' condition, steps were actually : operator action steps such
that rather than the. operator ensuring; conditions, he 1{; ' needed to perform actions.
f-2,. The L admin.istrative process for the. procedure change con-p tributed to this; event. -Initial; condition step 4 had been b slightly revised af ter POSRC review to incorporate'aL POSRC
comment.
The revised wording made, the step unclear and-contributed to the operatori error.
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w . L ~_ s . V i l-h made and the procedure change was incorporated without subsequent review by the original procedure reviewers, the ' POSRC, or any other qualified reviewers.
Reviews subse-
quent to POSRC review and approval "with comment" are not
required as a part of the licensee's administrative ! , process.
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The procedure as written did not adequately address the abnormal alignment of SW and service water cooling for No.
r 12 EDG.
Prior to procedurr, implementation it was not recognized that operator actions were required to open valves that would have closad in the event of a loss of offsite power.
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- The inspector reviewed the interim actions taken to strengthen ! the procedure preparation and review process and to correct the contributing causes listed in items 1 and 2 and found them ade-a ,' quate.
Long term actions proposed to. incorporate the interim actions appear to be appropriate.
' The inspector. discussed the procedure inadequacy listed in. item 3 above with the POSRC Alternate Chairman.
The inspector ! -observed that this problem had not been presented to POSRC for
review.
The POSRC Alternate Chairman-subsequently discussed l this problem with POSRC apd problem reports were written to.
l address the' procedure inadequacy and to understand why it was t not-brought to POSRC for review.: The inspector assessed that - ' initial' licensee. actions.in identifying the issue were appro - priate.
However, subsequent measures were not taken to ensure that this problem was reviewed and corrected.-
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Damaged LPSI Pipe Supports ' ! On August 26, 1990,. the licensee' reported via the ENS system in
a-four hour report-that-the suction piping to' the No.11 and 12
> ' Low Pressure Safety-Injection (LPSI). systems had. damaged piping. , supports. Both LPSI system loops were declared inoperable since the system: could potentially fail in.a seismic event.
The licensee entered the appropriate technical specification action statement.- Subsequent analysis determined that the damage would: ,, L not have prevented the system from performing as required.. The licensee-response ~'is described in Section '7.1 of this report.. -
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Inadvertent Auto-start of Unit 1 :2a Reactor Coolef,t Pump On August 21, 1990, the Unit I reactor coolant pump (RCP) 12A inadvertently started when equipment tagging :ersonnel racked in the breaker for the RCP 12A, The control switch for the pump was in the pull-to-lock position.
Althoven ne alarms were received in the control room, the operators cuickly identified the pump had started and within one minute, they stopped the pump by opening the RCP bus feeder breaker.
Af ter discussions , with the pump motor vendor and inspections of motor components, the licensee determined that the inadvertent start of the pump did not adversely affect the operability of the pump.
The licensee's investigation identified that a-maintenance request (MR) was written on August 20, 1990, af ter the closing spring failed to discharge as the breaker for the RCP 12A was racked out for tagging to support another MR.
The electrician who identified the problem hung a deficiency tag on the breaker cubical door and informed the tagging supervisor and a mainten-ance planner. It was also determined that this' problem was dis-cussed during the 6:45 a.m.
maintenance planning. meeting on August 21, 1990.
Later on the same day, while restoring the tagout on the breaker, the equipment tagging; personnel appar-ently did not see the deficiency tag on the cubical door. When the breaker was. racked iri, the pump started.
The licensee concluded that the root causes of the event were ineffective communications and monitoring of equipment status.
. A contributing f actor was a-deficient procedure which required removal of the trip-circuit fuses when racking in 13kv-breakers.
The licensee has subsequently revised the procedure and verified 'that other procedures were. not af fected. Also, steps.were taken by the licenseeEto strengthen the operations instruction and the electrical maintenance procedures for racking breakers.
To' address the' identified root cause.:the licensee is. developing.
corrective actions to improve their-ability to fully assess and-communicate the' safety consequences of deficient' equipment when-generating an.MR.
The. inspector determined that the licensee's - root' cause investigation was thorough 'and comprehensive. How ever, the inspector. expressed a-concern that-interim measures were not evaluated to preventi recurrence' Station management
,- agreed and ; indicated that initiatives were ongoing to address o this concern.
The inspector had no further questions.
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P_lant Operations With Inadequate Ultimate Heat Removal Capabi h ty On September 10, 1990, the licensee reporte: via a 10 CFR 50.72 notificet %h that on at least one occasion,an July 1988, they would nave been unable to reject post design tesis accident heat
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loads.
The licensee also indicated that previous criteria for i cleaning marine fouling from the service water heat exchangers were not conservative during periods of elevated bay tempera, ' , tures.
Licensee actions to implement the necessary criteria regarding service water fouling is discussed in Section 7.5 of this report.
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Loss of Shutdown Cooling On September 12,1990, at 1:45 a.m., the licensee reported to the NRC via the emergency notification system that the unit 1 i shutdown cooling system had automatically isolatad.
The unit was in mode 5 at the time with reactor coolant system (RCS) pressure being maintained between 100 to 250 psi and a bubble e established in the pressurizer.
The shutdown cooling. System < isolated when operators inadvertently allowed the RCS pressure . to reach the 280 psi isolation setpoint. Operators immediately I secured both the operating shutdown cooling pump and the pres-surizer heaters. RCS pressure was reduced and shutdown cooling - in was restored within two minutes. No increase in RCS temperature was-noted during this event, The inspector reviewed the control. room strip charts and dis- , cussed the event with the operators involved.
The - applicable I operating procedure requires RCS pressure to be maintained under
250. ps1.. ~ The. safety injection tanks (SIT) were pressurized to.
approximately 200 psi and operators had previously observed RCS ' .inleakage : from: the tanks.. Because of. the' inleakage, which was ' indicated by a steady-level: increase in the volume-control: tank, J e-the operators. were keeping-RCS -pressure high~ in: the band, H ' usually between 200_.and 250 psi. RCS pressure was controlled L manually. by the use of-pressurizer heaters. While' raising the: -1 l[, . RCS pressure above the SIT tank oressure, the. operator became ' d'stracted and allowed-RCS pressure to-increase to approximately ' i 50 ' psi. When-the~ operator noticed that the isolation ' valves -
i for the : shutdown cooling : system.were beginning to cycle close,. he ~ secured the ' pump.
Auxiliary spray was -initiated to reduce
u{ pressure and allow restart of the pump.
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g ... L h [c The' preliminary results from the licensee's investigation indi-cated that the root cause of the event was an operator error.
A contributing factor in this event was that an alarm function for the computer point P103A, pressurizer pressare indication, was not activated when it was added to the computer in April,1990, thus the operators received no warning that t ressure was out of L the desired band. The licensee has initiatec a Human Perform-ance Evaluation System (HPES) investigation to fully understand
the root cause and contributing factors.
, , < l_ The inspector determined that the immediate operator actions to restore the shut down cooling system was adequate.
The safety i significance of the event was minimal considering the plant conditions at the. time of the event.
The inspector considers r ' this event to be a result of a lack of attention to details.
No additional concerns were identified.
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Inadvertent Reactor Vessel Draindown On August 30, while draining the reactor coolant-system to sup-
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port the repair of a reactor coolant pump seal, an unexplained
void formed in the top of the reactor vessel. Although draining had commenced when the void formed, level was still indicated in ' , the pressurizer. Licensee and NRC review of this incident con- . cluded that entrapped air within the control element drive mech-l
anisms. expanded to form the void.
The results of the special ' g NRC team that investigated the anomaly are included in NRC . !f Inspection Report 50-317/90-24 No additional concerns. were identified.
! El ' 3.. ' Radiological Controls ! q
- 3.1, Rad _1ological Event
< _ f On. September 10, 1990 at 8:50 a.m., the control room operators ' L . . declared a > radiological event due to a report from radiological con- ' ' trols personnel that the: area had become a high radiation area. The , . operators believed. that this was 'an-. unexpected condition' and imple- " mented _its Emergency Response Plan Implementing Procedure for_ an - unplanned radiation field. The inspector observed a critique -between . operations and radiological controls personnel regarding this event, i ?' The: critique identified that. the suspected' cause of the increased - p radiation levels was' resin-that had-entered the floor drains from the
spent resin dewatering system due to a defective screen. -It was also j ' determined.that : communications; needed to be strengthened between ' radiological" controls : and operations.. The - event : was terminated _ at; - about,9:30 a.m.; once operators ' understood the suspected cause of:the '
increased._ radiation-level s. The inspector noted that. licensee ' [ -response to this event was adequate.
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I 3.2. Routine Reviews I l During routine tours of the accessible plant areas,. the inspectors i observed the implementation of selected portions of the licensee's t Radiological Controls Program.
The utilization and compliance with special work permits (SWPs) were reviewed to ensure detailed descrip-tions of radiological conditions were provided and that personnel adhered to SWP requirements.
The inspectors observed controls of access to various radiologically controlled areas and use of person- ! nel monitors and frisking methods upon exit from these areas.
Post-ing and control of radiation areas. contaminated areas and hot spots,
and labelling and control of containers holding radioactive materials
were verified to be in accordance with-licensee procedures. Health
Physics technician control and monitoring of these activities were , determined to be adequate.
No unacceptable conditions were identified.
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Maintenance and Surveillance i
4.1 Maintenance Observation l The inspectors observed maintenance activities, interviewed person-
nel, and reviewed records to verify that work was conducted in accordance with approved procedures, technical specific 6tions, and ' applicable industry codes and standards.
The inspectors also ver- , ified that redundant components were operable, administrative con-I trols were followed, tagouts were adequate, personnel were qualified.
-; . correct replacement parts were used, radiological controls were pro- ' per,. fire protection was' adequate, quality control hold points were
adequate and observed, adequate post-maintenance testing. was - per-
formed, and independent verification requirements were implemented.
The inspectors-independently verified that ' selected equipment was ] properly returned to service.
> > Outstanding work requests were reviewed to. ensure that -the licensee U ' assigned appropriate priority to safety-related maintenance.
The , inspectors observed / reviewed portions of-the following maintenance j activities.. . a.
Cleanout of No.12 Service Water Heat Exchanger - ' The inspector observed-portions. of. the tube cleaning of the= No.
12 service water heat exchanger performed per PM ol-11-M-0-3.
' The_ inspector determined that adequate controls were in place - for material accountability, fire barrier removal, security, and
confined space. entry. The -inspector verified that control room.
. operators and personne1' performing the maintenance were familiar !! ' with procedural requirements for stopping work in the event of: - - i changes to saltwater system configuration.- No, unacceptable j conditions were noted.- J v , L
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Main Feed Regulating Valves Air Supply Modification I \\ The inspector observed portions of work to mocify the air supply
to the main feed water regulating vahes (MFRV) per MO ! 200-066-514A.
The modification was performee to reduce vibra- ! tions to the solenoid valves and air tubing in order to elimin-F ate loss of feed water transients induced by these vibrations, i The inspector observed that the workers were knowledgeable and ' performed the work in accordance with the procedure.
No unacceptable conditiens were noted.
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LPSI Pump Repair l The inspector observed portions of the reassembly of No.12 low . pressure safety injection (LPSI) pump per MD 200-054-006E.
This ' work supported Facility Change Request 88-031 to replace the r n LPSI pump teflon seals.
The work was done in accordance with ! the procedure and with appropriate radiological controls.
' Quality control requirements were met.
No adverse conditions l were noted.
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Instrument Loop Resistor Repair I E The inspector observed' portions of the soldering of instrumenta- ) tion loop resistors inside the remote shutdown panel for Unit 1, This work was performed as documented in MD 200-240-309A to i
-permanently solder connections that were previously crimped.
i.he : licensee had previously concluded that crimped connections-
L may have contributed to. failure of-a resistor in the reactor coolant _ system pressure' indication circuit. -No adverse condi-L.
tions.were noted.
! I 4.2 Surveillance Observation I L The inspectors witnessed' selected surveillance ~ tests 1 to. determine , whether properly approved procedures were in use, technical'specifi-j cation frequency and1 action statement requirements, were satisfied, < F 'necessary equipment. tagging was performed,--test instrumentation was in calibration'and properly used, testing was performed by qualified ,
- personnel, and: test results satisfied acceptance criteriaE or were
properly dispositioned.
Portions of the' following; activities were,
, reviewed.1 ' g . Check Valve Testing.
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- 0n : September 9,1990,.the inspector witnessed portions.of'
i , x L Engineering Test Procedure 90-40, " Low Pressure'. Safety. Injection i p' Check Valve Slam"; The purpose of this test was.to-measure the ' -pressure pulses generated and the resulting pipe response when a' j check valve in one of the -two LPSI' pump discharge lines closes - i .. 'at various. flow-rates.
As discussed ~. in' Section 7.1 of. thi s -
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, [ ,> U report, the licensee has conjectured that check valve slam was the cause of significant hanger damage in the system.
Engineer-ing had installed instrumentation to mea nce approximately twenty different parameters during this test.
The test was con-ducted by establishing various flow rates wuh both LPSI pumps running and then stopping the No. 12 LPSI pun The majority of the data was collected at the LPSI common dit:harge header sup- , port R-16.
' The inspector observed relatively good coordination during the ~ test.
Both the operations and engineering staf f displayed a L working knowledge of the test method and objectives.
Data col-
lection was extensive and well documented.
The results of the test indicated only minor movement at a com-bined flow rate of 800 gallons per minute (gpm).
The LPSI flow L was subsequently increased to 1500 and 3000 gpm and a signifi-cant increase in pipe movement was observed.
Station engineer-ing concluced that the piping and supports were adequate to ensure operation during the anticipated transients.
This con-clusion= was presented to the site safety committee during meet-ing 90-141 and no additional concerns were identified.
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_MSIV Stroke Testing, STP-0-1 and MSIV Partial Stroke Testing, SfP-0-47-1 On August.30, 1990, the inspector observed selected portions of Unit 1 Main Steam Isolation Valve (MSIV) Stroke Testing. During , the tests -- of. Nos. 11 and 12 MSIVs, the licensee identified i several deficiencies.
The licensee discovered that No.11 MSIV stopped 1 inch short of fully open during the opening stroke.
, The licensee postulated that the MSIV did not fully open due to _
binding caused by degraded packing and excessive packing L gland ~ . torque. The licensee repacked and retorqued the valve, but the MSIV again stroked short of fully open by about 0.5 inch. The licensee was unable to - correct this deficiency - The _ licensee - concluded that-the inability of.No.11 MSIV to fully openL was . not safety significant since-the safe position of the MSIV is closed and no abnormalities were observed during -the closing > stroke..The licensee deter _ mined-that the current condition of _ the MSIV was sufficient.to pass rated steamt flow ~and - readjusted
the open : limit-switch to; indicate full -open.
The inspector- " observed that the incomplete seating of'No.11:MSIV may restrict , the licensee's flexibility to, if' desired, repack the_MSIV while " . steami_ng. The. - inspector - found no significant adverse-l , , . conditions ; ' - , ! x 'Y' s , ,
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l .. ? !o During the stroke test of No.12 MSIV, the licensee experienced problems in the MSIV hydraulic oil system and control circuitry
which prevented proper valve operations. The licensee corrected , the deficiencies and subsequently rutsted the MSIV satisfactorily.
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The inspector found operator response to the ceficiencies to be ' appropriate. Coordination between operations and engineering to i address the deficiencies was appropriate.
No noteworthy find, , ings were identified, t p c.
The inspectors reviewed -the following additional activities: ! !i P . STP-0-55-1, containment Integrity Verification, Modes 1-4 l -- STP-0-55A-1 Containment Integrity Verification. Mode 6 -- - h- , cSTP-0-71-1, Staggered Test of "B" Train Components ' -- i.
STP-0-73K, Containment Spray Pump Operability Verification ' -- p and Full Stroke Test of Minimum Flow Check Valves t ' STP-M-522-1, 4 KV UV Relay -Calibration and Response Time -- Test . - ! p 'No. noteworthy findings were identified from this review, .l ' > . 5.
- Emerge _ncy Preparedness
r > The finspector ' routinely toured the _ onsite emergency response facilities ! and discussed program implementation with the applicable' station person- < , p nel.
The resident l inspector had no noteworthy findings during this: inspection period.
.. i f 6.
-' Security _ ' During routine inspection tours, the inspectors observed implementation ofi e L portions-of. the; security. plan.. Areas observed - included access. point k search equipment operation,. condition of-physical barriers,~ site ' access control,: security forcel staffing, and response-to. system alarms and u, !L degraded conditions.. These' areas. of program implementation were - deter- ~! k mined to be adequate.
TFe. loss 1of the secondary alarm station and the
failure of the security diesel generator:are described in Section 2.3.a.. ' . . No~ unacceptable conditions'were identifiedc ( ' . , h
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Engineering and Technical Support The inspector reviewed selected design changes and modifications made to , the ' facility which the licensee determined were not unreviewed safety ' questions and did not require prior NRC approval as described by 10 CFR ! 50.59. Particular attention was given to safety evaluations, Plant Oper- " t ations Safety Review Committee approval, procedural controls, post- ._ modification testing, procedure changes resulting from this modification, ' !- operator training, and UFSAR and drawing revisions.
The following
activities were reviewed: ' 7.1 Damaged LPSI Pipe Supports
! -During restoration of the No.12 LPSI pump, after modifications, the p licensee experienced dif ficulty with alignment between the pump suc- ! tion and the suction piping flanges.
While adjusting the pipe ! F hangers to perform the alignment, the licensee noted that there was . cracking and spalling in the concrete under the base plates of the i:
- pipe hangers in several different locations. Most of the cracks were
associated with the base plate support of " spring can" type hangers but cracks were also found around one base plate anchor bolt for each.
of two rigid supports.
'.The licensee. performed an analysis to determine operability of the system assuming that these anchor bolts were not installed.
The analysis-demonstrated that the supports and the system were operable.
The inspector observed that the rigid supports had been previously inspected by the licensee and questioned-why these cracks.had not keen previously identified as a part of the LPSI' system check valve i am project. (This project was discussed in NRC Report 50-317/ 3i8/90-13.)' The licensee determined that:the previous inspection had .noted the cracking and had evaluated it.as; acceptable. The licensee is' reviewing the need : for additional criteria ~ for' inspection for cracks: of this nature to eliminate' ambiguous evaluations... As of the close~ of the-inspection, the licensee was evaluating.' permanent-repairs ~. to the piping supports.
No unacceptable conditions were identified.
- 7.2 Reactor' Coolant System Sulfates The _ chemistry - department noted _ an unexplained increase in Uni _t 1 '
reactor coolant system sulfate ~ concentration' - begi nni_ ng, August.10L 1990 - - Concentrations went from 4.7 ppb on August 10 to a peak of c 117 ppb on August 27. ' Samples of. the CVCS. ion exchanger ef fluent showed that ;this. system was. removing' the. sulf ates.
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concentration was reduced to 20 ppb by September 3. The identifica-I , E tion of the source of the sulfates and reduction of the concentra-tions was made a startup restraint by the licensee.
The licensee , later determined that there was not a safety or regulatory impact.
The most likely source of the sulfates was determhed to be released ! from material used in the maintenance of No 11 LM i pump. The POSRC reviewed this issue and resolved that it was ne longer a startup . restraint.
~ The inspector also reviewed the status of the plant chemistry depart- ' r ment.
There are currently seven fully qualified technicians, four of , whom are senior technicians.
Two chemists are also assigned to the i department.
Five additional technicians are in training and two of these should be qualified in the fall of 1990. Although the workload , for the group was high, the additional staff in training should ! reduce this workload when fully qualified.
' 7.3 Auxiliary Feedwater Recirculation Pipinj < During an engineering review of the Auxiliary Feedwater (AFW) System, i the lic e see discovered that the pressure rating for AFW pump coolers ! was less than the nominal inlet _ pressure and cooler relief valve ' , settings. The licensee concluded that cooler integrity had not been compromised since the coolers were originally tested at a pressure >
- "
greater than the nominal inlet pressure.
The licensee's proposed
corrective actions included removing the cooler relief valve from the j , system and throttling the inlet relief valve to establish the desired e " inlet pressure. The inspector reviewed licensee activities and found ' that they should adequately address the issue.
The inspector found -- no unacceptable conditions.
' . 7.4 -Erosion / Corrosion of Steam G nerator Thermal Sleeves-E During. work ' on No. 22 Steam Generator (S/G), the licensee found.
excessive erosion / corrosion = < of the thermal sleeve.- The erosion /. t corrosion, resulted in a wider gap between the-thermalc sleeve outer c diameter and the nozzle inner diameter than originally designed. The ' licensee replaced the. thermal: sleeves of the Unit 2 S/Gs,'however the.
- Unit 1-5/G. thermal sleeves were not replaced and may have experienced-
= similar problems.
To address this concern, the licensee evaluated ,
- the significance of the wider gap upon the. susceptibility of-the S/G
> , L nozzle to a water hammer event,- The licensee also considered the.
[ presence - of degraded thermal sleeves upon the inf.luence of thermal - (
- fatigue Land the-possibility that 'further eroding could cause damage W
.to S/G tubes due.to loose or broken parts, k
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i L The licensee evaluated the effects of worst case operational , transients and concluded that system design and procedures were ade-
quate for reducing the likelihood of steam gentrator water hammer ! events despite the increased gap size. The licenne also performed a
t thermal fatigue evaluation assuming that the, thermal sleeve was ! removed and thermal loadings were directly app 1'ed to the nozzle.
! ' ' The results of calculations made through the ene of the Unit 1 fuel
Rl cycle, show a conservative thermal fatigue usage factor (0.45) that ! is within the maximum code requirement (1.0).
The licensee's loose ~ part evaluation considered the S/G internal configuration and postu-i- lated the impact force that a conservatively weighted sharp metal ! piece would apply to the S/G U-tubes.
The licensee concluded from this evaluation' that the eroded thermal sleeve piece would not vio-late the pressure boundary of S/G tubes.
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The inspectors found that the licensee's activities were thorough,
well. documented and appropriately addressed the technical aspects of - this issue. The inspectors examined the thermal sleeve removed from No. 22 S/G, received a briefing on work methods and inspected the i, licensee's mock-up for repairs to the nozzle, distribution box and ' feed ring for Unit 2 S/Gs. The inspectors concluded that the per- ! sonnel involved in this project were knowledgeable and their activ-ities were conservative and safety conscious.
The inspectors noted i no unacceptable conditions.
7.5 Salt Water System Performance . k' The. inspectors followed the resolution of issues pertaining to the j F ability of the. salt. water system to remove the necessary heat.during- .t postulated fouling and heat conditions'. It was during this' ef fort
' that; the -licensee discovered.that previous operation was conducted
( during a period when the ultimate-heat removal capability. was
'
- seriously degraded.
' ' ' The licensee actions - to resolve this issue have; been extensive-and -
- comprehensive. Significant technical resources were devoted'to this.
' [p . issue during the recent outage.
'A program L to monitor the-heat' ' i removal capability L and assess' operability has_ been. developed -and I L' implemented prior to Unit 1 restart. The. inspector reviewed the heat t y ' exchanger ' monitoring program and discussed contingency actions.with:
' members of the licensee staff, Resolution of.the problem was deter-P . mined.to be acceptable for. unit-restart with no remaining _ questions- ' or concerns, ' h
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' p , 7.6 10 CFR Part 21 Report on a Reactor Coolant Pump Seal Housing In a letter dated September 10, 1990 Sulzer Binoham Pump, Inc. ad-vised the NRC of a defect condition on a reacter coolant pump seal housing supplied to the Calvert Cliff s Units 1 and 2.
The condition was first observed by the licensee on July 29,10%, on Unit 1, dur- ! ing an evolution to draw a bubble in the Unit 2 pressurizer.
The defect was manifested by failure of the seal to stage.
Followup ' , testing by the licensee engineers on August 10 and August 23, 1990, , , confirmed the condition observed previously. As a result, arrange-
ments were made to extend the Unit 1 outage upon completing saltwater
' system modification, to replace the pump seal and determine the root cause of the seal failure, , On September 1,1990, RCP 12A seal cartridge was removed for evalua- - tion and testing.
Testing on the seal cartridge showed that it was ( performing as designed.
However, further evaluation of the seal i housing revealed the source of the unusual pressure readings. A seal housing is utilized in the new seal design in order to allow the i Byron-Jackson pump to accept the Sulzer Bingham seal.
The licensee, > with guidance from the vendor representative, determined that the . controlled bleedoff inlet hole was inadvertently drilled through the r entire housing wall during the manufacturing process.
The hole - , should have been drilled to the center of the wall to converge with the vertical controlled bleedoff flow hole.
This defect apparently was'not identified in the vendor's quality control process.
! The licensee repaired the housing onsite, under guidance from the [ vendor _ and with approval from the licensee's Nuclear _ Engineering _
' Department, by installing a plug and cover-weld to the housing.
The
l licensee. plans, to' perform visual examination of all four Unit 2 ' " ' reactor coolant pump-seal housing assemblies within the next_ few ' - weeks.. Verification.of 'the other three Unit 1. reactor ' coolant pump j p seal housing assemblies has been accomplished by proper seal. staging- ' and function during pump operations.
' 'The vendor informed Southern California Edison of the housing problem 'since a similar design was '. installed at San-Onofre. Units.' 2 and 3.
j' ' The inspector found no unacceptable conditions.
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' ' 8.
Safety Assessment and Quality Jerification
, L 8.1 Plant Operations and Safety Review Commi+. tee
L The inspector attended several Plant Operations-and Safety Review Committee (POSRC) meetings.
TS 6.S requirements for required member
attendance were verified.
The meeting agendas in:1uded procedural changes, proposed changes to the TS, Facility Cha'nge Requests, and
minutes f rom previous meetings. Items for which adequate review time ,, was not available were postponed to allow committee members time for l further review and comment.
Overall, the level of review and member , participation was adequate in fulfilling the POSRC responsibilities.
l L 8.2 Review of Written Reports i n k Periodic and Special Reports, Licensee Event Reports (LERs), and ' i Safeguards Event Reports (SERs) were reviewed for clarity, validity, accuracy of the, root cause evaluation and safety significance ! description, and adequacy of corrective action. The inspector deter-
mined whether further information was required.
The inspector also i . verified that the reporting requirements of 10 CFR 50.73, 10 CFR t b 73.71, - Station - Administrative and Operating, and Security Procedures, ' and Technical. Specification 6.9 had been met.
The ;following reports . [- were reviewed: } LER 90-21 Appendix R Cable Sepc ation for Emergency Diesel ' ! ' Generators t LER-_90-22 ' Low Temperature Overpressure: Calculation-Problems
LER 90-23 . Engineered Safety Features Actuations Due to Failed [ . Fuses and Power Supply-
, No unacceptable conditions were identified.
8.3 Startup Review Board: 'The inspector ~ attended the licensee Startup Review Board ($ URB) con-- E -T ducted. on -September 10,'1990.
The purpose of-this meeting was to - ascertain. plant. readiness for entry into mode 4.
The SURB was con-
ducted 'as described in .the Unit: :1 .Startup Plan,: -dated ! , , LAugust= 28, 1990.
l - The SURB. committeeJ recommended to -' the ;planth manager - that restart-should-proceed pending resolutionf of the1 items previously > identified i <, H' . and' tracked by1 an: appropriate administrative process. ~ Managers of - .the various departments demonstrated an: adequate questio_ning attitude.
during the SURB process.
The inspector concluded.that the-.SURB was.
ef fective in providing-a forum-for~ open - discussion of the problems _ r that' need resolution prior to -unit,. restart.
No ' concerns were 1dentified, , . .l ' l A _ _:
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' I i 8.4 Controlled Plant Orawing Deficiencies ' The controlled plant drawing deficiencies had been identified as a concern both in the licensee's Unit 1 Startup Assessment Report, . dated May 29, 1990, and in NRC inspection report 50-317/90-08 and ! 50-318/90-08. Approximately 110 non-conformance reports (NCRs) were ' generated on various plant drawing deficiencies during the period of l January 1, 1990, through June 30, 1990. Although problems with draw- ! ings are not new, this large number of NCRs in a relatively short ' , period of time can be attributed to an increased sensitivity and ! aggressive. documentation of problems by licensee personnel.
During i the same period, the licensee experienced the following plant events and "near-misses" which can be attributed partly to drawing defici-encies: 1) loss of an auxiliary boiler causing loss of condenser , vacuum, * 2) drained 1,200 gallons from the spent fuel pool, 3) work ' - was begun on a hand switch that was still energized, and 4) a poten-f tial existed for tagging out the wrong saltwater header.
t 'The licensee had initiated a "Significant Incident Finding Team" l (SIFT) investigation on May 11, 1990 in response to the above events
to understand the extent of the problems and to develop recommenda-tions to correct the problem. The SIFT focused its efforts on deter-mining the adequacy of electrical equipment tagging and a review of
the drawing revision process. At the end of this inspection period,. r the SIFT assessment was incomplete and its.' initial conclusions and i " recommendations were rejected by the Plant Operations Safety Review
- Committee (POSRC).
Based on discussions with both SIFT and POSRC t members and review of preliminary SIFT conclusions, the inspector i , determined that the scope of the SIFT. investigation was--too narrowly ' t l focused and the identified root causes were vague and inappropriate.
.[ The licensee management-informed the inspector-that further evalua -
tion of the rootL eauses and recommendations by'the SIFT'will be com- ' ' ' pleted within the next few weeks.
The i licensee is currently _ relying ion -the experience level of the operations ;and tagging. personnel, as, well. as-additional compensatory measures: in the equipment. tagging. process, -to identify drawing
, , 1 deficiencies.
The s tagging personnel are' required to review and com- " ' . pare all: associated drawings 'and references, :includ_ing the; computer < ized equipment tracking. system, as deemed appropriate by the tagging group - supe'rvi sor. - Any discrepancies found --in. reference, materials , . used in preparation of the tagout require; resolution-by'the Design Engineering and/or ystem Engineering Groups.
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The licensee has solicited assistance from a contractor engineering firm for a detailed technical review of the 167 controlled drawing related NCRs which were generated in the last 18 months to determine safety significance and generic implications. TM s review concluded p that each individual deficiency has minimal safety significance and, g with a few exceptions, does not affect the operacility of the asso-F ciated system er component.
However, a general concern for lack of L details was noted in instrument installation drawings and non-safety related lighting panel drawings.
, , if The inspector independently reviewed 15 of the 167 NCR packages, including associated drawings, and concurred with the licensee's con-clusions.
The inspector determhed, however, that the identified H deficiencies in the aggregt.te indicate a need for increased attention.
8.5 Inadequate _ Controls for Fire Doors , in recent months, the licensee experienced repeated problems with fire doors ' fcund either blocked or taped open, Following are some examples of the problems that_have occurred: 1) on February 24, 1990 '12' charging pump room fire door was found blocked open; 2) on March9, 1990 'll' charging pump room fire. door was found taped open; 3) on June 14, 1990 '22' charging pump room fire door was.found - blocked open: 4) on July 13,1990 'll' charging pump room fire door
was found tied open; and 5) on August 22, 1990 '12' charging pump room door was found taped open.
L In response to the last two incidents described above, the licensee.
[ management ' initiated a-root cause analysis that included the human ~ performance evaluation system (HPES); The licensee's short term cor-- e rective action. included posting a guard by the charging pump room L areas to ensure the doors are. not-blocked or fastened open.
Also, L all site tupervisors: briefed their employees on the requirements and.
L importance ' of controls on fire doors'.- As.a long term. corrective : , action, a-multi-discipline task force was-formed ~ to evaluate and implement HPES recommendations.
As part of this :- ef fort, licensee engineering personnel-have been directed to assess decontrol of the, doors while in modes 5 and 6.
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! The inspector determined that the licensee's ongoing corrective ! actions and the path for resolution appeared appropriate.
However, ' the inspector expressed concern to licensee management that problems with fire door controls clearly indicate a weakness in management attention. This item is unresolved pending the licensee's complete ' implementation of the longer-term corrective actions (UNR 50-317/ 90-23-01 and 50-318/90-23-01).
8.6 Procedures Upgrade Program ' In February, 1989 Baltimore Ga, and Electric (BG&E) implemented a - procedures upgrade program (PUF) to address a declining performance due in part to poor procedure. quality. This program was reviewed by ' m., the NRC in March,1989 during a special team inspection (STI) which found a number of significant deficiencies in the upgrade program-
(see Inspection Report No. 50-317 cnd 50-318/89-200 for details).
The licensee's response to the STI's findings included the following ' commitments: , --- -management would periodically re-emphasize their expectations regarding procedure compliance to all personnel;
PUP-would receive the highest priority (management attention and ' -- resources) allowed to any task in the Performance Improvement . Plan (PIP);
PUP would incorporate lessons learned from developments in' pro- ' -- cedure upgrading practices; and, ,
- .
an individual' was assigned as program manager to provide con- -- t trol. program direction and consistency of management.
.! 'The licensee's October 27,1989 letter-detailed ~ the close-outi of ' ' " restart commitments related to-the. PUP.
A. project plan - dated '
_ November 3,1989. laid' out 'in some detail the size: of. the project, , procedure ~ hierarchy,. task list and a number of. project' control features to: ' --- (establish at single procedure hierarchy to-in'stitutionalize ! management processes, , provide position interface controls; and, -- t ' upgrade both~ administrative and technical procedures for accuri -- 'D acy: and. functional adequacy using human = factors considerations .
as appropriate.
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F A review of certain aspects of the PUP conducted in late 1989 (see ' Inspection Report Nos. 50-317/89-25 and 50-318/89-26 for details) by resident and regional NRC inspectors determined that a number of ' problems still existed with Procedure CCI-101, "Calvert Cliffs Imple- , menting Procedure Development and Control". Program controlling pro- [ cedures were not yet in place and criteria assurin that deficiencies ' identified in biennial reviews were corrected prior to procedure use were not defined. Additional NRC concerns with C01-101 were noted in , Inspection Report No. 50-317/318/90-02 regarding procedure revision, ~ L review and approval. in March,1990, the NRC found that PUP progress ~ had been satisfactory to support startup and safe operation of Unit 1, but that certain significant elements of the project were either ' being revised or were r.ot complete, preventing an overall assessment of the effectiveness of the project (see Inspection Report No.
50-317/318/90-05 for details).
During this inspection period, the NRC conducted an inspection of the Procedures Upgrade Project to assess overall performance, focusing on the following areas; project management, includino :,cneduling and resources; -- procedure development process and control, including procedure -- quality, review, approval and validation; . licensee. corrective actions and deficiencies noted in earlier -- inspection reports; and, b conformance to PIP Tast Action Plan No. 5.2.1.
.-- [ The findings for the above areas are detailed below, Project Management g The PUP. is. directed ' by. a BG&E general; supervisor who reports to -the f . Manager - Outage and Project Management-Department.' Reporting to the ~ ._ PUP project manager areitwo project supervisors, one responsible for [ an administrative; procedures' program, and the second-responsible for handling the technical procedures program and project administration, - Each supervisorJ directs the-activities-of< both licensee. and contract ' u , e-personnel in-procedure-developmenty -and project administration-(including scheduling and analysis) and enhancement.
Since the bulk-V E P of the upgrade ef fortLis in -the technical' procedures area, Lapproxi- .mately a dozen task managers.(all 'of who are BG&E employees). report-- U jngs to the' technical procedures programLsupervisor, coordinate, pri- , p orit.ize and-. monitor procedure development for.. their assigned proced-K' .ure groups. The procedure writers are-a' mixture of. licensee and con-e tract personnel; procedure reviewers are -licensee personnel only.
LDetails 'of responsibilities and authorities are contained in the PUP.. Project Plan.
' ~
' l i Ji L' ' , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _., ,- o.; o- , t-s gg t e The inspector determined that the project was being managed effec-tively. Deficiencies noted in previous inspection reports (irs) had been evaluated and appropriately resolved.
For example. IR No, . 50-317/318/89-200 noted that there was no sense of ownership for the project or the finished product (procedure). In interviews with task managers, the mangers expressed strong support for the program and stated that on the whole the upgraded procedures had been well accepted.
An exception to this general acceptance was noted in the mechanical maintenance and I&C areas, where some personnel felt that the upgraded procedures were too detailed and did not take credit for the " skill of the trade".
They acknowledged, however, that the upgraded procedures were considerably improved over previous revisions.
, Another deficiency regarding unrealistic scheduling was also noted in IR No.- 50-317/318/89-200.
This concern was based on the fact that . milestones were extended for significant periods.
The licensee's
current project schedule was reviewed and except for electrical and L ' control maintenance procedures, which have a considerable backlog, the draf ting of upgraded procedures is either on schedule or ahead of schedule. The task manager for this group stated that a large number of maintenance data packages used to support generic instrument cali-bration. procedures would be removed from the. upgrade scope (since they were not procedures) which should result in a significant drop , in the total number of procedures yet to be drafted.
With-the exception of mechanical maintenance procedures, reviews of draf ted procedures were behind schedule. -These reviews were being conducted by the _mo3'e experienced personnel in - the affected disci-pline (generally.SR0s in operations and' senior technicians in E&C).
These reviews were assigned in addition to their regular duties, The.
. inspector noted that this observation was essentially the same as one .made in IR No. 50-317/318/90-05.
It appeared that the licensee had not. adequately ~ resolved this issue -in order to support the December, 1992 completion date, Upgraded procedure approval appeared to follow L the same trend as procedure review, =The licensee indicated that the~ scheduled completion date, while E ' ambitious, was still: achievable and that once Unit 1 was in7 opera- .. ! tion, additional personnel should belavailable for procedure reviews,- ! . , D i m .'
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l o . Project administration has been significantly enhanced. For example, ' the addition of two project supervisors (one of whom had experience - from a similar upgrade project at another facil'ty) had freed the project manager from many of the day-to-day districtions of detailed i supervision. Most of the technical writing groups.nad been relocated i centrally, in temporary trailers near the main 6::ess.
Previously,
E the groups were scattered throughout the site, f%cn of the remainder ,. of the PUP group was to be similarly moved.
Computer programs were ' being used to develop appropriate data bases, augment project task . ,, tracking and procedure quality feedback, and to identify disconnects , in existing work practices.
A maintenance program procedure hier-archy pilot program had been developed incorporating these enhance-i ments to demonstrate the ef fectiveness of such.
It was being evalu-ated by the licensee at the time of this inspection.
Based on the , above, the inspector concluded that licensee management has estab- ' i - lished firm control over the procedures upgrade program.
Procedure Development Process and Control ! The licensee is developing a hierarchy of procedures to organize, in order of authority, documents that control management processes, starting with a statement of authority and descending through program .; directions to, ultimately, individual section or unit procedures.
l While not all elements of the hierarchy were in place, the two con- ! ' trolling procedures for the PUP, Calvert Cliffs Instruction (CCI)
100M, " Preparation and Control of Calvert Clif fs Instructions" and ' CC1-101N, "Calvert Cliffs Implementing Procedure Development and > Control", have been approved and issued.
The inspector reviewed both procedures in detail and determined that i _ 'the two procedures should provide a sound and effective means to con-trol procedure - draf ting,- review and. approval, and changes.
For [ example, there was only one writer's guide. 'It -applied to all pro- -; cedures except the emergency operating procedures (EOPs), which had l L the#r own. guide due to the required-special format'. The reviewLand.
- L approval process was clearly defined, with appropriately assigned
' ' responsibilities.
The -licensee had implemented a 1" qualified reviewer . program" (discussed. in the following paragraph)' to streamline the i review process. The inspector noted that concerns raised in previous.
l - L inspection reports (Nos. 50-317/318/90-25 and 50-318/89-26, 50-317/ - 318/90-02 'and 50-317/318/90-05) had ; been appropriately ' addressed, - For; example, the-previous revision of CCI-1011did not prohibit the e same' person' from being both1 originator 'and reviewer.
This practice - F is now prohibited. Another. previous concern noted that the perform- ! 'ance of ~ 10 CFP 50.59 -safety-review screening had not been adequately
. addressed in CCI-101M. Attachment 6 of CCI-10lN now provides' a step- . by-step guide to determine whether a safety evaluation is required, j l l- > )
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i The attachment appeared adequate, provided that the evaluator had been trained in its use (see the following assessment of the ' qualified reviewer program).
However, a related concern in IR No.
50-317/318/90-05 did not appear to be adequately addressed. CCI-101N
did not include a method to formally document how a reviewer's com-ments were addressed by a procedure writer other than a checklist ' (Attachment 5).
CCI-100M provided a document comment sheet which would contain both the reviewers comments and the writer's resolution
of those comments.
j As noted above, the licensee had implemented a qualified reviewer
program which was intended to reduce the procedure review workload on I
the Plant Operations Safety Review Committee (POSRC) to allow POSRC to concentrate on other issues having a significant impact on plant- < safety.
CCI-166, " Qualified Reviewer Certification", provided for the selection, training, certification and de-certification of per-sonnel in the program.
The program appeared generally effective, however, several deficiencies were noted. While the initial training ' for a -prospective reviewer appeared. adequate, no provision had been made for periodic requalification training. The licensee agreed that requalification training should be included and that CCI-166 would be revised accordingly. Also, until a technical specification amendment incorporating the. qualified reviewer program was approved, POSRC would continue to review procedures.
The licensee stated that pro-cedures would also be reviewed and screened by qualified reviewers in order to gain practical experience.
POSRC would perform a quality check of. the review-and screening.
It was -not clear, however, how this, quality check was to be performed or documented.
Qualified - reviewers - received pre-implementation ' training on both CCI-100M-and
CCI-101N, including procedure screening for
CFR 50.59 applicability'. b A. review of the. responses to-several practice screenings (01-40, ' change - 90 401; and. 01-17C, change 90-405) indicated personnel had difficulty _ in making the appropriate determination in several key areas.
For example, when determining if.the change would cause . equipment operation in a manner that violates-a technical specifica-tion, o five personnel answered yes, seven no. Similar inconsistencies were noted regarding the impact on' the Final. Safety Analysis-Report (FSAR). The inspector reviewed.the lesson plans-developed by the PUP staff for the pre-implementation. training and found that 10 CFR 50.59 screening was adequately described.
The inconsistency in responses to screening questions, however, indicated that training had not been effective-in ensuring a uniform screening, quality.
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, ' As noted in IR No. 50-317/318/90-05, upgraded procedures were sub-sta.tially improved over previous revisions.
The inspector noted that the procedure writers appeared well qualified to prepare pro- ' cedures in their assigned area.
Procedure qualuy was to be mon-itored by the responsible task manager and any-adverse trends or conditions noted in the bi-weekly status report :- the PUP project manager.
An internal project procedure, PUP 007, 9rocedure Evalua-tion", provided adequate means to monitor procedure cuality; however, the inspector was concerned that this mechanism was not available in ' a station procedure and could therefore be discontinued when the PUP project was completed. The PUP project manager acknowledged the con-cern and indicated that the appropriate elements of PUP 007 would be incorporated in 0C1-100/101.
l Summary The licensee had implemented a procedure upgrade project which appeared to be capable of producing good quality procedures and would provide adequate controls over procedure review and changes.
A significant number of discrepancies noted in earlier inspection-reports had been resolved and appropriate corrective actions taken, , The project met the objectives of a number of activities contained in , Phases l' and 2 of the -licensee's performance improvement plan (Sec- ~ " tion 5.2.1).
Several minor deficiencies were noted in the project, related to inadequate training / experience of some personnel.in the qualified reviewer program; and a longstanding dif'iculty in obtain-ing timely reviews.
The inspector noted that slow reviews had the potential to delay project completion.
. Based on the findings detailed - above, the inspector concluded'that the licensee's. procedure upgrade project ~ adequately addressed and-resolved the concerns. noted in the ~ Special Team Inspection.- No unacceptable conditions were noted.
> . .9.- Followup of Previous Inspection Findings a Licensee actions - taken in response to open items and findings from pre ' 'vious inspections were reviewed.
The inspectors determined if corrective-7~ actions were appropriate and' thorough and previous concerns were resolved.
- ltems were closed where the inspector determined; that_ corrective actions?
.wouldJprevent recurrence.
Those items for which additional licensee- . action was ' warranted remained open.
Tha iollowing items were reviewed.
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a. , i ' 9.1- (Closed) UNR 50-317/89-80-01 and 50-318/89-80-01 ! The management of Calvert Cliffs had promulgated a policy that the t Emerger.cy Operating Procedure (EOPs) were to be used as guidelines rather than insisting on verbatim compliance. The licensee. changed the policy by including in their Calvert Cliffs Instruction (CCI) 300K, "Calvert-Clif fs Operating Manual (CCOM)," the requirement for " Verbatim Compliance." Walkdowns of E0Ps 3 and 4 verified the imple-mentation of the verbatim compliance requirement.
Thi s item is closed.
9.2 _(Closed)UNR 50-317/89-80-02 and 50-318/89-80-02 The current E0P-2, " Loss of Of fsite Power," did not incorporate the
Loss of Forced Circulation guideline consistent with the Combustion Engineering Owner's Group (CEOG). list of Emergency Procedure Guide- - lines (CEN-152, Rev. 2). The loss of forced circulation is addressed t i in the Abnormal, Operating Procedure (AOP-3E), " Natural Circulation," l and appears in the diagnostic event flow chart in E0P-0, " Post-Trip _ !- -Immediate Actions." AOP-3E has been revised to include a step that ! has the operator perform the same safety status. check found in E0P-2.
[ The: inspector reviewed E0P-0 and A0P-3E and confirmed the above, j ' Furthermore, the inspector confirmed the fact'that CEN-152, paragraph ! - 12.3, allows the change to an A0P when it pro'vides-the same informa, 'o
tion.
This item 'is closed.
-1 }< 9;3' (Closed) UNR 59-317/89-80-04 and 50-318/89-80-04
, s E0P-6-diagnostic flow chart was event based rather than._being symptom. base'd!as required by CEOG. -The flow chart was revised to be symptom a based-and._ training for the operating crews was completed ion October 17,L1989. The inspector / reviewed the revised flow chart, the c
training lesson ' plan, and the time and attendance sheets, and was ' $
- satisfied with the-actions taken. -This-item.is closed.-
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- 9.4.(Closed)UNR 50-317/89-80-05 and 50-318/89-80-05
[ . ? The effectiveness of thec E0Ps-was determined lto be impaired in_ that - S N
- E0P-8' ~includesc the. status Eof ~ the vital auxiliaries --inithe - Safetyi 16, FunctionLStatus Checks, but-E0P-8 has no operator actions or refer-'-
- ences ' to procedures _ La :how to= recover ' a vital' a'uxi.liary that may be i F' ' lost. 'The licensee has ' included a. section within E0P-8 for the r recovery orLrestoration of-vital auxiliaries, _The inspector reviewed W the, section', '" Vital L Auxiliaries," and' found - the subjects was ade-'-
quately addressed. This item is closed.
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s 9.5 (Closed) UNR 50-317/89-80-07 and 50-318/89-80-07 Inconsistencies existed between the simulator and the control room.
The inspectors rs viewed and verified that the 4 consistencies were corrected. These inconsistencies included the nois.e level and light-ing in the simulator and the binding of the, documentation in the control room. This item is closed.
9.6 { Closed)UNR 50-317/89-80-08 and 50-318/89-80-08 . ... A number of deficiencies were identified in the Calvert Cliffs writers' guide. These deficiencies were corrected and satisfactorily implemented; eg., the action verb list was revised, the alphanumeric system and procedure substeps have been corrected, and the AOPs will , be written in the same format as the E0Ps.
This item is closed.
{ '9.7 (Closed) UNR 50-317/89-80-09 and 50-318/89-80-09 An inadequate verification and validation process existed for E0Ps.
= { Actions taken include the development of a writer's guide for E0Ps
' .and A0Ps with increased ' emphasis on the process; the increased
involvement by the Training Department, and the inclusion of human ' factors elements in the process to insure verbatim compliance.
The ! - inspector reviewed the actions and consider them adequate. This. item
q is closed, j 9.8-(Closed) UNR~50-317/89-80-11 and.50-318/89-80-11 The methodtrur indicating that a. copy of a procedure and operator aid: ~ are controlled has been inadequate.
Corrective action' for. control-- l , 4J ling E0Ps and. plaques located on the control room panels were found I by the inspectors totbe adequate. Diagrams (placards) concerns were ' ' c also reported in -Inspection-Report (IR) 50-317/89-07 7(UNR 50-317/. .j . ' 89-07-01). and. closed out in IR 50-317/89-18'. This item is-closed, i . j-9.9' (Closed) UNR'50-317/89-80-12 and 50-318/89-80-12 - + . Lack of interfaceiaction Letisted between the organizations, involved' dl
in:the-maintenanceLof E0Ps CCI-101Niadequately: details the respon-sibilities and' interface c' the-different. organizations involved in - "m . the. maintenance of E0Ps. Thetnew AOP and the futureLEOP/AOP writer's, 9l ^. guide also address the organizational-responsibilities.
TheLinspec- ' _ tors verified athat. organizations such as~ the5 Nuclear Engineeringi , ~ , - System L Department were submitting :their supporting L documents -- for.
j E0Ps, 'eg., uNuclearl Engineering.. Operating ' Procedures (NEOPs) to Lthe - j u ' ' '
ProcedureL Development and Modificetion Acceptance Unit- (PDMAU), o
- Maintenance ' of EEOPs andt AOPs 'are the responsibility of PDMAU.~- This*
u item is' closed.
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-l 9.10 (Closed) UNR 50-317/90-05-01 and 50-318/90-05-01 An NRC inspector observed that two anchor bolts were missing from the fixed end of the Unit 1 Component Cooling Heat Exchanger No. 12. The inspector was provided a summary of actions taken and conclusions - regarding the missing bolts. Futurs actions by the licensee included ensuring that adequate safety evait ations were performed and that the original safety margins were maintained.
The reviewing inspectcr found that the safety evaluatior3 were adequate and the original design safety margins were maint ained. As a good engineering prcc- ! , tice, the licensee installed a " clamp" designed to resist an uplift force. This-item is closed, j l 9.11 (Closed) UNR 50-317/90-13-01 and 50-318/90-13-01
This licensee identified issue pertained to the ability of the equip-ment in the - electrical switchgear rooms to perform _under certain ' + temperature and air conditioning scenarios.
The inspector reviewed a 'the engineering analysis performed to bound the _ problem and the com- _ h pensatory measures implemented to assure-adequate room cooling. The ! , licensee is currently processing-a revision to the technical specifi- -{ cations;to require more stringent controls regarding room temperature J and air co'nditioning equipment availability.
These controls have been Limplemented a_s an - administrative requirement in the interim.- ._The inspector _had no further questions. This item is closed.
4 9.12 (Closed) UNR 50-317/90-09' ] and 50-318/90-09-01 This. issue pertained to the fouling of 'the service water ' heat. exchangers and _the resulting degradation of their ability to remove j the necessary ; decay _ heat.
The inspectors reviewed the: licensee-j analysis #and compensatory measures implemented to ensure adequate - I
heat exchanger performance'as detailed in section 8. above. A _ review
of the specific engineering analysistand the previous system perform- -ance will be' performed as -an inspection cof unresolved item! 50-317/J n 90-11-01 and 50-318/90-11-01.
This-unresolved = item >is' closed.
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m, _; D.3e? . h violations-or deviations were identified. An unresolved item was - $ng@. W J - identified regarding weakness-in controls for fire-doors Poor pro-i gress, was observed regarding the resolution of druing deficiencies, - . ' y 1 m - p + ' n . dl.g 10.2 Attendance at' Management Meetings-Conducted by Region Based-13 m Inspectors W' . . Inspection Reporting ' ~ 7-LDate~ Subject-wnc , _ Report No.
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50-317/90-22~ R. Laura ,p , _ Testing.
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