IR 05000317/1993017
| ML20046D075 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/02/1993 |
| From: | Gray E, Lohmeier A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20046D069 | List: |
| References | |
| 50-317-93-17, 50-318-93-17, NUDOCS 9308160102 | |
| Download: ML20046D075 (11) | |
Text
-
.-
i
.
.
!
U.S. NUCLEAR REGULATORY COMMISSION REGION 1
y DOCKET / REPORT NOS. 50-317/93-17
'
50-318/93-17 i
LICENSE NOS.
DPR-69 LICENSEE:
Baltimore Gas & Electric Company FACILITY NAME:
Calvert Cliffs Nuclear Power Plant Units 1 & 2
.
'
INSPECTION AT:
Lusby, Maryland INSPECTION DATES:
June 14-18,1993 (at site)
July 12-16,1993 (at Region I)
I INSPECTOR:
A. Lohmeier, Sr. Reactor Engineer Date Materials Section, EB, DRS
,
APPROVED BY:
M E
E. H. Gray, Chief, Chief Date
.
Materials Section, EB, DRS
.
!
.
.
!
!
.
'
9308160102 930810 PDR ADOCK 05000317 G
PDR '
'
-
---
. -
.
-
I
.
l
.
Areas Insoccted: The scope of this inspection covered the assessment of engineering and technical support activity at the Calvert Cliffs Nuclear Power Plant (CCNPP). Included in the assessment were corporate direction of engineering, engineering organization focus and responsibility, performance trends in the nuclear engineering and plant engineering divisions, self assessment and root cause analysis of problem areas, review of open items and licensee event reports for engineering weaknesses, review of plant operation safety review committee i
(PORC) activity, control of engineering contractors, modification implementation, issue resolution, fatigue cycle management activity, and i. plementation of recent system m
improvements.
Results: The licensee demonstrated that reorganization, management changes, and focus of j
activities at CCNPP are resulting in many improvements to the safe and efficient operation of CCNPP. CCNPP has a comprehensive means to direct nuclear and plant engineering efforts toward safe and efficient plant performance such that performance goals were generally being met together with improving trends, the self assessment efforts of CCNPP individual business organizations are effective in identifying substandard trends for corrective action, the presentations before the POSRC committee were well prepared, adequately presented, and the committee members participated into the issues in depth, the quality of the LERs was high and reports were comprehensive. Open items are being effectively addressed and closed, the licensee has initiated several excellent actions to improve system performance, i
licensee contractor control through a performance reporting system is good, the licensee is aware of current industry concerns related to fatigue cycle monitoring of reactor coolant system components, the licensee uses off-shift engineering coverage to provide for more effective response to plant concerns, and the licensee demonstrated ability of engineering to provide comprehensive modification packages and issue resolution programs.
i l
l
)
l
i
-
.
.
DETAILS 1.0 SCOPE OF INSPECTION The scope of this inspection included the assessment of engineering and technical support activity at Calvert Cliffs Nuclear Power Plant (CCNPP). Included in the assessment were corporate direction of engineering, engineering organization focus and responsibility, performance trends in the nuclear engineering and plant engineeling divisions, self assessment and root cause analysis of problem areas, review of open items and licensee event reports for engineering weaknesses, review of plant operation safety review committee (PORC) activity, control of engineering contractors, modification implementation, issue resolution, fatigue cycle monitoring activity, and implementation of recent system improvements.
2.0 FINDINGS (37700)
2.1 CCNPP Goals and Engineering Organization Focus The inspector noted that CCNPP goals for 1993 are being achieved through continual quality improvement, including improved safety, power generation levels, improved INPO and NRC assessments, and control of operational and maintenance expenses. For the long term, the licensee expects satisfaction of these goals to position CCNPP to operate up to and possibly beyond its current lifetime, including preparations for decommissioning.
During the current SALP period, the inspector found that a change in management of the plant and nuclear engineering division management was implemented which provided for an exchange of management experience between plant and nuclear engineering together with an overall change in focus of engineering efforts. The new focus provides for emphasis and priority on those engineering efforts contributing immediately to continued safe and efficient operation of the plant. Longer range programs will carry lesser priority.
The inspector found that licensee emphasis on personnel improvement at CCNPP has been through objectives established for improved organization, enhanced awareness of safety issues through 10 CFR 50.59 safety evaluation training, and high quality operability determinations.
Licensee programs having high priority toward safe event free operation include procurement for high availability of high quality parts, improvement of procurement timeliness, and improvement of requisition processing time by shortening delays in procuring material.
Review of the trends in each of these areas by the inspector showed significant improvemen.
t
!
Industry experience has been used by the licensee to improve plant performance through reduced backlog of unprocessed Significant Operating Event Reports (SOER), streamlining l
the SOER process, providing a weekly newsletter, and improving teamwork. The inspector
'
noted that open SOER recommendations have been reduced, maintenance orders on engineering delay have shown a decreasing average response time, and temporary plant alterations and modification backlogs have been reduced.
Material conditions of various systems have been improved by the licensee to decrease system unavailability. Systems needing improvement have been identified through a system improvement study. These include auxiliary feedwater, saltwater, emergency diesel generators, and chemistry systems. Examination of the resulting operational trends by the inspector show improved availability of each of these systems. The thermal performance of Unit 1 has improved.
In view of the foregoing focus of engineering and technical support activity, the reorganization and management changes at CCNPP have resulted in many improvements to the safe and efficient operation of CCNPP. The emphasis of the licensee on programs having immediate results in reducing challenges to the system appears to be a sound approach. The effect of lowering priority of longer range initiatives, however, will only be apparent in the future.
2.2 Assessment of Engineering Performance
' Nuclear Engineering Department (NED)
The inspector reviewed the May 1993 Monthly Reports of business function performance of NED and the Design Engineering Section (DES). The reports cover progress made by the engineering in satisfaction of four goals, namely to improve safety, improve self, INPO, and NRC assessments, and manage operations and maintenance expenses.
NED appears to be meeting the goals at the rate established for 1993 with one exception,
,
'
reducing Plant Design Maintenance Orders on Engineering Hold. Through the tracking system, this problem has been identified by the licensee and seen as a consequence of increased outage work load.
Design engineering shows improving performance in all measured items except for increasing action item backlog, increasing non-standard source backlog, and increasing drawing change request backlog. The backlog increases are not significant and appear to be due in many instances to the effect of a large work load during outages. These areas are being identified by engineering management so that resources can be applied to prevent the backlogs from -
becoming unrecoverable.
l l
,
,
..
.. -..
.
.
.
Plant Encineering Section The inspector reviewed the May 1993 Monthly Reports of CCNPP Plant Engineering Section (PES) performance. The reports cover progress made by PES in satisfaction of four goals, namely to improve safety, improve self, INPO, and NRC assessments, and manage operations and maintenance expenses. The inspector noted that the number of root cause analyses was not meeting the limits set by PES goals. The licensee stated that this was due to the increased workload over the outage period.
Review of the CCNPP plant engineering performance measurement system by the inspector indicate a comprehensive means is available to direct nuclear and plant engineering efforts toward safe and efficient plant performance and that the performance goals were generally being met together with improving trends. Areas where goals were not met were largely indicative of the sensitivity of the performance measurement to the increased level of
workload during planned outages.
2.3 Engineering Self Assessment The inspector reviewed the operation of the Independent Systems Evaluation Group (ISEG)
in assessment ofissues requiring trending of a series of related problems with common causal factors that lead to a generic concern. Trends are identified by the individual business functions and progress through the stages of potential trends, active trends, trends turned over for responsible corrective action, and closed trends.
Review of the first quaner 1993 trend report with the licensee indicated trends for which corrective action was in process include welding errors and documentation, procedure non-j compliance, foreign material exclusion, Quality Verification / Quality Engineering (QV/QE)
i notification prior to maintenance, reactivity control, poorly structured procedure information, l
drawing control / print accuracy, and parts traceability. Potentially negative trends included set-point control, design errors by improper engineering judgement, oversights, and calculations, and problems affecting multiple components. Trends closed subsequent to appropriate corrective action include valve misposition events, fire protection eqmpment i
'
problems, and procedural violations.
The self assessment efforts of CCNPP individual business organizations and the trending of i
'
significant issues by ISEG are an excellent means of identifying significant negative trends, providing for corrective action in a prioritized manner, assignment of responsible organizations for the corrective action programs, and closing out the corrected issues of negative performance.
-
..
. -
- - - -. -
. -
- - - -
.
i
.
2.4 Plant Operations Safety Review Conunittee (POSRC)
The inspector reviewed the activity of POSRC at CCNPP by attending a regular POSRC meeting. Topics covered at this POSRC meeting included results of analysis of supervision meeting requirements of ANSI N18.1, evaluation of as-built configuration associated with moisture / separator /rcheater second stage vent lines, revision of electrical design standard to provide 25% full load margin prior to cable derating, evaluation of problems experienced during checkout of SFP crane, and briefing on fire related compensatory measures to secure control room HVAC system operability.
The inspector noted that the presentations before the POSRC committee were well prepared, adequately presented, and committee member participation was penetrating. In some cases, the presentations were not accepted, pending further information required by the committee to make evaluations and judgements.
2.5 Review of Licensee Event Reports and Open Items The inspector reviewed recent licensee event reports of CCNPP. The reports covered a wide range of issues including inoperable fire dampers, main steam safety valve settings, valve action range testing intervals, pump recirculation flow isolation for tesung, isolated phase bus duct system ground fault, failed main condenser expansion joint, saltwater loop inoperability, inadvertent relay actuation, reactor trip due to hydraulic system malfunction, manual trip due to a sticking MSR relief valve, loss of control room air conditioning, and high pressurizer safety valve set-points.
Review of the root causes of these events revealed a wide range of deficiencies not related to a single weakness area. The root causes include: personnel error (2 cases), inaccurate vendor technical data, inadequate design information, inadequate drawing information, insufficient refrigerant inventory, failure of MSR relief valve seating, hydraulic problems or mechanical binding, incomplete corrective actions, inadequate work scheduling procedures, torn main condenscr expansion joint belt, insufficient specifications and procedures provided, and test procedure lack of precision.
The individual root causes above represent weaknesses including vendor error, design and drawing error, maintenance error, not following procedures, inadequate procedures, and component failure. The list underscores the necessity for each element of the plant to strive toward perfection of its own specific responsibilities.
The inspector noted the trend of LERs has shown considerable improvement. During the first two quarters of 1993, there have been 3 LERs per quarter. This is below the levels experienced during 1989 and 1990, where the quarterly average was from 5 to as high as 12.
The inspector also noted that the quality of the LERs was high and found the reports to be comprehensive, providing description, cause, analysis of the event, and the corrective action take.
The inspector reviewed the current NRC open items list dated 06/14/93. There are 8 EDSFI items related to the commitments made during the EDSFI inspections. These items have been addressed by the licensee engineering department and their resolution is awaiting NRC review.
2.6 System Improvements The inspector reviewed licensee actions to improve system performance. As a result of a system improvement study, the licensee identified major systems requiring improvement.
Those identified are the auxiliary feedwater system, salt water system, emergency diesel generators (EDGs), and chemistry systems. As a result of actions taken, the inspector noted from performance trend charts that feedwater unavailability has been reduced,' salt water system unavailability has been reduced, no failures of the EDGs to start have been experienced on both units in the last 100 starts, and the effectiveness of chemical sampling
'
systems and monitoring capabilities of condensate demineralizers has increased.
2.7 Engineering Contractor Control The method used to control engineering design contractors was reviewed. The system used is to grade the contractors on a quarterly basis. The system provided for fm' ancial penalties if the performance was below expectations. Licensee experience with this system of contractor control was good and is used as a consideration in awarding new business to the contractor.
2.8 Fatigue Cycle Monitoring Program The inspector reviewed the licensee's Fatigue Cycle Monitoring program. A long term goal of CCNPP is to operate up to and possibly beyond the current license operating period. The program of cycle counting is an approach to ensure that components will not be subjected to fatigue cycles during the plant license lifetime exceeding those for which they have been designed. This program will also assist remaining life determinations during assessments of license extension by recognizing the number of cycles remaining within the component's lifetime.
Calvert Cliffs Instruction (CCI) 513 provides for the recording of transients / operating cycles.
Implementation of these instructions is reflected in the Mechanical Discipline Training given
,
at CCNPP. This program, as currently implemented, is consistent with, and goes beyond, the requirements of Technical Specification Section 6.10 requiring retention of transient operation records for the duration of the operating life of the facility.
The inspector noted the awareness of the licensee of current concerns of ASME Code Committees, Pressure Vessel Research Committees, EPRI, and NRC with the environmental effects on the fatigue life of nuclear power generation plant components. They me alert to any design change consequences of these concern.
.
2.9 Engineering Interface with Operations A major initiative by the engineering divisions has been the addition of back-shift coverage to plant operations. Under this initiative, design and plant engineers (electrical, I&C, mechanical, civil, plant support) are at the plant to provide for immediate action on the second shift and Saturdays. Third shift and Sundays are covered by engineers on a call basis. In an interview of the operations superintendent, the inspector was told of the improvement of engineering response resulting from the initiative and the positive effect this j
had upon plant operations, A description of 26 instances of back-shift coverage was reviewed by the inspector. The result of this initiative is to ultimately reduce out of service time due to waiting for the next shift. Action statements are written immediately. From the documented instances of off-shift coverage, the inspector observed the increased effectiveness of engineering support at CCNPP.
2.10 Modification Package and Issue Report Review The inspector reviewed the modification package for FCR 87-90, Digital Feedwater Control System, which will replace the analog feedwater control system with a control grade full range digital feedwater control system. The inspector reviewed the modification package including the design review, POSRC presentation,50.59 evaluation, and design input record.
The reviewed material showed ability of engineering to pmvide a comprehensive modification package on an important system improvement.
The inspector reviewed the licensee response to the calibration errors found in the Rosemount transmitters as reported in NRC Inspection Reports 50-317/318/92-23. The problem was that the static pressure effect was not applied correctly to Rosemount instrument calibrations. The problem was found through issue reports and root cause analysis.
Research of the Rosemount proposed transmitters found that baseline knowledge was
inadequate and the vendor technical manual was unclear. Corrective action included correction of the calibration data, training, and improvement of the vendor manual.
Engineering provided a comprehensive program in solution of this engineering problem.
3.0 UNRESOLVED ITEMS i
Unresolved items are matters about which more information is required to ascertain whether they are acceptable items or violations. The closing of an unresolved item previously defined in Inspection Report 50-317/318/92-32 is discussed below.
i I
__
_ _ -
.
i e
.
'
3.1 (Closed) Unresolved Item 50-317/318/92-32-01 The bolting on the emergency diesel generator explosion doors had not been properly installed with washers having sufficient thickness to sustain the bolt loading on the flange.
To address this problem, the licensee replaced the washers with those of sufficient thickness
to allow transfer of loading from the bolt to the flange. The inspector observed that the bolting is now adequate and has been installed in a workmanship-like manner. This item is closed.
4.0 CONCLUSIONS Reorganization, management changes, and focus of activities at CCNPP are resulting
in many improvements to the safe and efficient operation of CCNPP (section 2.1).
Nuclear and plant engir.eering performance goals were generally being met together
with improving trends (section 2.2).
The self assessment efforts of CCNPP individual organizations are effective in
identifying substandard trends for corrective action (section 2.3).
The presentations before the POSRC committee were well prepared, adequately
presented, and the participation of the committee members was penetrating into the issue (section 2.4).
The quality of the LERs was high and reports comprehensive. Open items are being
effectively addressed and closed (section 2.5 and 3.0).
Licensee contractor control through a performance reporting system is good (section
2.7).
The licensee is aware of current industry concerns related to fatigue cycle
management (section 2.8).
The licensee uses off-shift engineering coverage to provide for more effective
'
response to plant concerns (section 2.9).
Engineering provided comprehensive modification packages and issue resolution
programs (section 2.10).
i i
.
.
.
5.0 MANAGEMENT MEETINGS The inspector met with licensee representatives at the entrance meeting on June 14, 1993, and at the exit meeting on June 18, 1993, at the Calvert Cliffs Nuclear Power Plant in Lusby, Maryland. The names of licensee personnel contacted is shown on Attachment A.
Personnel with names shown with an asterisk attended the exit meeting.
The findings of the inspection were discussed with licensee management at the June 18,1993, exit meeting. The licensee did not disagree with the findings of the inspector.
-1
,
l i
%..
.
,
ATTACIIMENT A The following personnel were contacted during the inspection or at the entrance and exit management meetings (asterisks indicate attendance at the exit meeting):
Baltimore Gas and Electric P. G. Chabot Technical Support Manager C. H. Cruse Plant General Manager
B. Doroshuk Principal Engineer, Life Cycle Management, NED
M. Gahan Principal Engineer, Design-Civil Engineering, NED
P. Katz Manager, NED T. R. Lupold Principal Engineer, P&SV, Plant Engineering Section
W. D. Maki Compliance Engineer D. Muth Compliance Engineer
R. L. Szoch, Jr.
Principal Engineer, Design & I&C Engineering, NED
L. J. Tucker General Supervisor, Plant Engineering Section
R. Waskey General Supervisor, Design Engineering, NED
J. O. Wood Senior Engineer, Quality Audits
United Stntes Nuclear Renulalary Commission
- K. Lathrop Resident Inspector i
.
<