IR 05000317/1993013
| ML20045B545 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/09/1993 |
| From: | Briggs L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20045B540 | List: |
| References | |
| 50-317-93-13, 50-318-93-13, NUDOCS 9306180055 | |
| Download: ML20045B545 (3) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-317/93-13; 50-318/93-13 License Nos.
DPR-53/DPR-69 Licensee:
Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203 Facility:
Calvert Cliffs Nuclear Power Plant, Units I and 2 Location:
Lusby, Maryland Inspection conducted:
April 25,1993, through May 29,1993 Inspectors:
Peter R. Wilson, Senior Resident Inspector Carl F. Lyon, Resident Inspector Henry K. Lathrop, Resident Inspector s P Nd<.m 4, f/f3 Approved by:
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r Larry IyBriggs, Chief" Date Reactor Projects Section No. I A Division of Reactor Pmjects Inspection Summary:
This inspection report documents resident inspector core, regional initiative, and reactive inspections performed during day and backshift hours of station activities including: plant
operations; radiological protection; surveillance and maintenance; emergency preparedness; security; engineering and technical support; and safety assessment / quality verification.
Results:
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See Executive Summary.
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9306180055 930614
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PDR ADOCK 05000317 G
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SUMMARY Calvert Cliffs Nuclear Power Plant. Units 1 and 2
Inspection Report Nos. 50-317/93-13 and 50-318/93-13
Dant Operations: (Operational Safety Inspection Module 71707, Prompt Onsite Response
to Events at Operating Power Reactors Module 93702) Overall, both units were operated safely. There were no noteworthy operational events during the period. General plant
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housekeeping was good despite a high level of outage activities.
Radiological Protection: (Module 71707) Based on direct observation of access controls and radiological safety practices and discussions with radiological controls personnel, the radiological protection program and implementation were excellent. Particularly noteworthy was BG&E's effort to remove some highly radioactive residue from under the Unit 2 upender assembly. The job was thoroughly planned and executed.
bfaintenance and Surveillance: (Maintenance Observations Module 62703, Surveillance Observations Module 61726) Some maintenance program enhancements were reviewed. A process was effectively implemented to ensure that past due safety-related preventive maintenance activities were evaluated for operability considerations. BG&E's guidance for performing and evaluation the root cause for component failures was well defined. BG&E has implemented an effective maintenance technician training program and has nearly completed the upgrade of all maintenance-related procedures.
Emercency Preparedness: (Module 71707) An acceptable level of emergency preparedness was found based on inspection of facilities, review of procedures, and discussion with operations and emergency planning personnel.
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Security: (Module 71707) Based on direct observation, the security plan was generally professionally implemented. BG&E's compensatory measures for protected area lighting deficiencies were under NRC review as the period ended. This issue is unresolved.
Engineerine and Technical Support: (Module 71707) One fuel assembly was reloaded l
into the Unit 2 core with a potentially failed fuel pin due to personnel error. BG&E's
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decision to operate for the next fuel cycle without removing the assembly was made after extensive analysis and due regard for both nuclear and radiation safety.
Safety Assessment /Ouality Verification: (Modules 71707, 30703) Based on direct observation, the onsite and offsite safety review committees continued to demonstrate a good questioning attitude. Overall, the level of review and member participation was adequate in fulfilling the committees' responsibilities.
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DETAILS 1.0 SUMMARY OF FACILITY ACTIVITIES Unit 1 operated at full power with no significant events for the duration of the inspection period.
Unit 2 began the period defueled in a refueling outage. On May 8 the unit entered Mode 6 (refueling) with the commencement of core reload. Unit 2 entered Mode 5 (cold shutdown)
on May 21 following the tensioning of the reactor vessel head. The unit continued the outage in this mode for the remainder of the inspection period.
2.0 PLANT OPERATIONS 2.1 Ooerational Safety Verification The inspectors observed plant operation and verified that the facility was operated safely and in accordance with licensee procedures and regulatory requirements. Regular tours were conducted of the following plant areas:
- control room
- security access point
-- primary auxiliary building
-- protected area fence
- radiological control point
- intake structure
-- electrical switchgear rooms
- diesel generator rooms
-- auxiliary feedwater pump rooms
- turbine building 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 offsite power sources was verified. The inspectors observed various alarm conditions and confirmed that operator response was in accordance with plant operating procedums.
Routine operations surveillance testing was also observed. Compliance with TS and implementation of appropriate action statements for equipment out of service was inspected.
Plant radiation monitoring system indications and plant stack traces were reviewed for unexpected changes. I.ogs and records were reviewed to determine if entries were accurate and identified equipment status or deficiencies. These records included operating logs, turnover sheets, system safety tags and temporary modifications log. Plant housekeeping controls were monitored, including control and storage of flammable material and other potential safety hazards. The inspectors also examined the condition of various fire protection, meteorological, and seismic monitoring systems. Control room and shift manning were compared to regulatory requirements and portions of shift turnovers were observed.
The inspectors found that control room access was properly controlled and that a professional atmosphere was maintaine e
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In addition to normal utility working hours, the review of plant operations was routinely conducted during backshifts (evening shifts) and deep backshifts (weekend and midnight shifts). Extended coverage was provided for 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> during backshifts and 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> during deep backshifts. Operators were alert and displayed no signs ofinattention to duty or fatigue.
The inspectors observed an acceptable level of performance during the inspection tours detailed above. General plant housekeeping was good despite a high level of outage activities.
2.2 Followup of Events Occurring During Insoection Period There were no notable operational events during the inspection period.
3.0 RADIOLOGICAL CONTROLS During tours of the accessible plant areas, the inspectors observed the implementation of selected portions of the licensee's Radiological Controls Program. The utilization and compliance with special work permits (SWPs) were reviewed to ensure detailed descriptions of radiological conditions were provided and that personnel adhered to SWP requirements.
The inspectors observed that controls of access to various radiologically controlled areas and use of personnel monitors and frisking methods upon exit from these areas were properly implemented. Posting 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 BG&E procedures.
Health Physics technician control and monitoring of these activities were determined to be good. Overall, an excellent level of performance was observed.
3.1 Crud Removal On May 22,1993, while performing a prejob radiation survey in the Unit 2 refueling pool north cavity, a radiation safety technician (RST) discovered unexpected high radiation levels in the vicinity of the refueling upender assembly. When the RST observed his radiation monitor go off scale high (0-5 R/hr scale), he immediately exited the area and notified his i
supervisor. Radiation protection personnel promptly prohibited access into the north cavity, l
posted the area as an exclusion zone, and conducted extensive radiation surveys. These surveys found localized radiation areas as high as 5000 R/hr. Examination of the affected
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area with a remote camera revealed a deposit of highly irradiated residue (crud) under the refueling pool upender assembly.
The inspectors closely monitored BG&E's actions to decontaminate the affected area which was complicated by the location of the crud. BG&E's preferred method was to use a remotely operated, modified vacuum cleaner to capture the crud. BG&E also developed two s
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contingency plans if the vacuuming process was unsuccessful. The second option was to wipe the affected area from a remote location with cloths and the last option was to shield
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the area. All of these options required some personnel to work in radiation fields of approximately 400 mr/hr to operate the removal equipment.
The inspectors reviewed BG&E's ALARA evaluation and the special work permit associated l
with the decontamination effort. The ALARA evaluation was detailed and thorough. -lt contained the requirements for job prerequisites, radiological controls, prejob brief, the job process, and the postjob requirements. The SWP detailed dressout and dosimetry requirements. The inspectors noted that the dosimetry requirements for the personnel
.l designated to remotely operate the vacuum were extensive, requiring special dosimetry on the-i head, chest, back, thighs, arms, gonads, fingers, wrists and ankles. In addition, the personnel were required to wear Teledose monitoring devices and alarming digital j
dosimeters.
BG&E developed a mock up of thejob site. The modified vacuum cleaner and other special j
tools were tested. Designated personnel also conducted dry runs to practice and refine the process.
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The inspectors attended the prejob brief, which was conducted by the Supervisor-Radiation.
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Control Operations (SRCO). The SRCO covered every aspect of thejob and ensured that all involved personnel had a thorough understanding of the job requirements and the radiation hazards.
The inspectors also witnessed a significant portion of the crud removal. The SRCO closely
supervised the work. The inspectors noted that all the required equipment was prestaged and
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that no personnel entered the high radiation areas until the SRCO was satisfied that all the job prerequisites were met.
j Attempts to remove the crud via the vacuum cleaner were unsuccessful. Personnel subsequently removed the crud using cloths on long poles. The workers placed the cloths in a shielded cask for long-term storage. Post job surveys confirmed that all of the crud had been removed. The highest whole body dose received for thejob was 280 mrem.
- At the close of the period, BG&E had not determined the source of the crud or why the crud was localized to the area under the upender. No similar occurrences in the past had been
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BG&E's actions regarding the discovery and removal of the crud were outstanding. Prompt action was taken to minimize personnel exposure upon discovery of the problem. The planning for the crud removal was extensive as evidenced by the use of mock ups and the development of contingency plans. BG&E demonstrated a strong safety perspective by requiring the use of special dosimetry, including Teledose monitors and alarming digital dosimeters. The supervision of the job by the SRCO was excellent.
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4.0 MAINTENANCE AND SURVEILLANCE 4.1 Maintenance Observation The inspector reviewed selected maintenance activities to assure that:
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the activity did not violate technical specification limiting conditions for operation and that redundant components were operable;
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required approvals and releases had been obtained prior to commencing work;
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procedures used for the task were adequate and work was within the skills of the trade;
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activities were accomplished by qualified personnel;
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where necessary, radiological and fire preventie cont.ols were adequate and implemented;
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quality verification hold points were established where required and observed; and
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equ;pment was properly tested and returned to service.
The work observed was performed safely and in accordance with proper procedures.
Inspectors noted that an appropriate level of supervisory attention was given to the work depending on its priority and difficulty. Maintenance activities reviewed included:
MO 29200191 Replace the 21 High Pressure Safety Injection pump seals.
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MO 29205127 Modify the Unit 2 steam generator blowdown circuitry for the Containment Spray Actuation System.
MO 28805559 Replace.2-RV-150, the boric acid pump minflow relief valve.
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MO 290050M Install actuator for 2MOV-6615 Main Steam Drain Line Isolation Valve 4.2 Surveillance Observation The inspectors witnessed / reviewed selected surveillance tests to determine whether properly approved procedures were in use, details were adequate, test instrumentation was properly calibrated and used, technical specifications were satisfied, testing was performed by qualified personnel, and test results satisfied acceptance criteria or were properly dispositione.
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The surveillance testing was performed safely and in accordance with proper procedures.
Inspectors noted that an appropriate level of supervisory attention was given to the testing depending on its sensitivity and difficulty. Notable observations are included below for selected activities. The following surveillance testing activities were reviewed:
STP O-4B-2 B Train Integrated Engineered Safety Features Test STP O-4A-2 A Train Integrated Engineered Safety Features Test STP O-4 was a complex test that established plant conditions to allow the shedding ofloads from a 4 kV safety bus, start its diesel generator, and sequentially load the diesel generator via the LOCI (loss of coolant incident) sequencer. The test required close coordination and timely execution by many test personnel in several departments. Inspectors attended the pre-evolution briefs and observed portions of the test trial runs and the actual STP performances.
A high level of management attention and supervision was noted. The briefs were
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comprehensive and well organized. The STPs were properly controlled and were executed in
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a professional manner.
4.3 Maintenance Procram Chances and Updates a.
Preventive Maintenance Activity Deferrals
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BG&E's preventive maintenance (PM) activity deferral process requires the responsible system engineer to perform an evaluation to determine what affect, if any, the postponement of a PM activity could have on system operability. In NRC inspection Report 50-317 and 318/92-23, the NRC found that BG&E's PM activity deferral process lacked a mechanism to ensure that deferrals and associated operability determinations were processed in a timely manner. During this period the inspectors reviewed the changes BG&E implemented to correct this weakness.
The inspectors found that BG&E had revised the PM program to require both a tracking mechanism for past due safety-related PMs and a process to ensure past due safety-related PMs were evaluated for potential operability concerns. The program changes required the PM coordinator to initiate an issue report whenever a safety-related PM activity was
postponed past its latest end date and a PM deferral had not been previously approved.
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BG&E's issue report system in turn required a prompt operability evaluation to be performed l
(see NRC Inspection Report 50-317 and 318/91-82). The inspectors reviewed a sampling of
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issue reports associated with past due safety-related PMs and found that in each instance an operability evaluation had been performed in a timely manner.
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The inspectors also reviewed the tracking mechanism and found that in all instances past due PMs either had an approved deferral or an issue report had been generated. The inspectors also noted that the total number of past due safety-related PMs was low. At the beginning of May,1993, there were only five past due PMs as compared to 25 at the beginning of the year.
In conclusion, the inspectors found that BG&E had effectively corrected the above weaknesses in their PM program. Past due safety related PMs were accurately tracked and operability evaluations were promptly performed as required.
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Root Cause Analyses In NRC Inspection Report 50-317 and 318/90-80, the NRC found that specific guidance for performing and documenting root cause analyses of component failures was undef' ed.
m During this period, the inspectors reviewed changes made by BG&E to correct this weakness. The review consisted of discussions with appropriate BG&E managers, procedure reviews, and examination of selected root cause analyses.
The inspectors found the guidance for performing and documenting root cause analyses in a Calvert Cliffs administrative procedure. Calvert Cliffs Instruction (CCI) 169, " Issue Report Initiation, Review and Processing," contained the criteria and process for initiating a root cause analysis (RCA) for a component failure. CCI-169 required personnel identifying a component failure or deficiency to initiate an issue report. BG&E's Issues Assessment Unit personnel were then required to screen the issue report using specified criteria to determine if the performance of a RCA was appropriate. Requests for a RCA were then required to be forwarded to the responsible manager for action. The inspectors concluded that the screening criteria were adequate to ensure that a RCA would be performed for component failures which could affect nuclear safety.
The inspectors also reviewed several selected RCAs. The RCAs were generally well documented and of high quality. In addition, the RCAs contained recommended corrective actions to prevent recurrence.
l In conclusion, the inspectors found that BG&E had taken effective corrective actions to correct the weakness described above. BG&E's guidance for performing and documenting RCAs was well defined.
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Plant Restoration Project Update In May,1993, BG&E initiated a plant restoration project to improve the material condition of both units. This included upgrading the flooring material in radiologically controlled areas, repainting, and relamping selected areas with higher intensity lighting. As of the end
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of the inspection period, the project was approximately 20 percent complet.
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The inspectors conducted detailed tours of the completed areas. Components such as valve stems and limit switches were found to be free of paint which could adversely affect
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component operation. The inspectors noted that the improved lighting has been effective in making housekeeping deficiencies easier to identify and correct.
BG&E informed the inspectors that the restoration project was scheduled to be completed at the end of 1995. The inspectors will continue to follow the progress of this initiative.
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Maintenance Training and Procedures Upgrade An NRC team inspection in May,1989, found that a significant number of maintenance procedures did not contain adequate details to ensure that activities were performed correctly.
A followup inspection in August,1990, noted a number of improvements introduced by the procedures upgrade program (PUP); however, an insufficient number of maintenance procedures had been upgraded to provide a valid assessment. In May,1993, the inspectors reviewed a number of mechanical and electrical and control maintenance procedures, as well as related technician training.
In reviewing selected maintenance procedures, the inspectors found the procedures to be clearly written and logically presented. The level of detail appeared appropriate for the complexity of the task. While most of the procedures appeared to be used as " stand alones,"
adequate references were included to facilitate procedure usage. Where used, data collection sheets were neat and appeared user-friendly. BG&E had completed upgrading 97% of the electrical and control and 86% of the mechanical maintenance procedures. Upgrades of the welding and instrument calibration procedures are scheduled to be completed by September 1993.
The inspectors also reviewed aspects of the maintenance technician training program currently in use at Calvert Cliffs. It appeared that job training for both new and experienced technicians was thorough and comprehensive. Both classroom and hands-on (either mock-up or on-the-job) training processes were used. Additionally, training equivalency
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determinations (TEDS), a two-step testing process, provide a means for supervisors to
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accurately assess individual abilities and readiness to perform a given type of job. The inspectors determined that the maintenance technicians appeared knowledgeable. They noted that the number of errors attributable to maintenance personnel during the past year was very low and that rework during the Unit 2 refueling outage was less than one percent, indicating that the training program has been effective.
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5.0 EMERGENCY PREPAREDNESS The inspectors toured the onsite emergency response facilities to verify that these faciliaes were in an adequate state of readiness for event response. The inspectors discussed program implementation with the applicable personnel. The resident inspectors had no noteworthy findings in this area. An acceptable level of emergency preparedness was found based on
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inspection of facilities, review of procedures, and discussion with operations and emergency j
planning personnel.
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6.0 SECURITY During routine inspection tours, the inspectors observed implementation of portions of the security plan. Areas observed included access point search equipment operation, condition of i
physical barriers, site access control, security force staffing, and response to system alarms and degraded conditions. These areas of program implementation were determined to be adequate except as noted below.
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10 CFR 73.55 requires, in part, that all external areas within the protected area be provided j
with illumination sufficient for the monitoring and observation requirements but not less than 0.2 footcandle measured horizontally at ground level. On May 10, 1993, the inspectors i
observed two trucks located within the protected area that did appear not to have sufficient lighting underneath to meet this requirement. BG&E security personnel measured the
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illumination under the trucks and found that the light under one of them was less !han 0.2 footcandle.
l BG&E security managers stated that adequate compensatory measures for lack oflighting and
other issues had previously been implemented. This issue is unresolved pending NRC review and evaluation of these compensatory measures (URI 50-317 and 318/93-13-01). In the interim, BG&E has placed temporary lighting under vehicles located within the protected area.
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l 7.0 ENGINEERING AND TECIINICAL SUPPORT
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7.1 Unit 2 Reactor Core Reloaded with Defective Fuel Assembly i
Following a full core off-load in February,1993, BG&E determined that nine of the 217 fuel assemblies had indications of potential leaks. BG&E's usual policy is to reconstitute any
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leaking fuel assembly to remove defective pins prior to re-use. However, due to personnel
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error, assembly 2K144 was reloaded into the core with a potentially failed pin. Core reload was completed and reactor vessel reassembly was in progress on May 18, 1993, when BG&E discovered this fact.
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BG&E's nuclear fuel manar,ement group performed an evaluation of the potential consequences of operating the unit for an entire cycle with a failed fuel pin. Because the fuel assembly was located at the periphery of the core and had already experienced very high burnup, the evaluation concluded that no significant radiological or operational impacts would result. Analysis by outage and radiological controls managements provided additional support to BG&E's decision not to replace the fuel assembly.
The inspectors discussed this event with BG&E management and reviewed the analyses used by BG&E to reach their conclusion. The fuel management group's evaluation appeared comprehensive and addressed the nuclear safety aspects of the issue, from both radiological and operational perspectives. The potential for further degradation of the fuel pin was also addressed. An assessment performed by the radiological controls group, based on previous experiences operating with failed fuel, indicated that a minimal radiological hazard to personnel would be created. BG&E was also conducting a root cause analysis to determine why the fuel assembly was reloaded prior to reconstitution. The inspectors concluded that BG&E management had thoroughly reviewed the issues surrounding operation with a failed fuel pin and had made their decision based on sound engineering judgment and concern for nuclear safety.
8.0 SAFETY ASSESSMENT AND QUALITY VERIFICATION 8.1 Plant Operations and Safety Review Committee The inspectors attended several Plant Operations and Safety Review Committee (POSRC)
meetings. TS 6.5 requirements for required member attendance were verified. The meeting agendas included procedural changes, proposed changes to the TS, Facility Change Requests, and minutes from previous meetings. Items for which adequate review time was not available were postponed to allow committee members time for further review and comment.
Overall, the level of review and member participation was adequate in fulfilling the POSRC responsibilities.
8.2 Offsite Safety Review Committee Inspectors attended portions of the Offsite Safety Review Committee (OS"RC) on May 28.
The OSSRC composition and agenda were in compliance with the requirements of TS 6.5.4.
The agenda included a review of violations of regulatory or procedural requirements affecting nucicar safety, and abnormalities in plant equipment performance that affected nuclear safety.
Overall, the level of review and member participation was suitable to fulfill the OSSRC responsibilities.
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9.0 MANAGEMENT MEETING During this inspection, periodic meetings were held with station management to discuss inspection observations and findings. At the close of the inspection period, an exit meeting was held to summarize the conclusions of the inspection. No written material was given to the licensee and no proprietary information reluted to this inspection was identified. BG&E did not object to any of the findings or observations presented at the exit interview.
9.1 Preliminary Insoection Findings One unresolved item (URI 50-317 and 318/93-13-01) was identified concerning the adequacy of security lighting under vehicles parked within the protected area, as described in section
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6.1.
9.2 Attendance at Management Meetings Conducted by Region Based Insoectors
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Inspection Reporting Dale Subject Beoort No.
Insoector
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4/30/1993 Initial 50-317/93-11 (OL)
R. Temps License Exams 50-318/93-11 (OL)
5/21/1993 Radwaste 50-317/93-15 J. Furia Transportation 50-318/93-15
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5/21/1993 NDE and 50-317/93-14 R. McBrearty Welding 50-318/93-14 H. Kaplan
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