IR 05000317/1993028

Insp Repts 50-317/93-28 & 50-318/93-28 on 930912-1009.No Violations Noted.Major Areas Inspected:Plant Operations, Maint,Engineering & Plant Support

ML20059M077
Person / Time
Site:	Calvert Cliffs
Issue date:	10/25/1993
From:	Boyle M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20059M064	List: IR 05000317/1993028 ML20059M063
References
50-317-93-28, 50-318-93-28, NUDOCS 9311180142
Download: ML20059M077 (14)

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U.S. NUCLEAR REGULATORY COMMISSION ,

REGION I

Report No /93-28; 50-318/93-28

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License No DPR-53/DPR-69 l

Licensee: Baltimore Gas and Electric Company l Post Office Box 1475  :

Baltimore, Maryland 21203 i

Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Location: Lusby, Maryland  ;

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inspection conducted: September 12, 1993, through October 9,1993 -

Inspectors: Peter R. Wilson, Senior Resident Inspector l Carl F. Lyon, Resident Inspector Henry K. Lathrop, Resident Inspector Ram S. Bhatia, Reactor Engineer, DRS 7x Approved by: I /d-26-73 Niichael L. Boyld/ Ac' ting Chief Date Reactor Projects Section No. l A Division of Reactor Projects Insocction Summary:

This inspection report documents resident inspector core, regional initiative, and reactive inspections performed during day and backshift hours of station activities including: plant l operations; maintenance; engineering; and plant suppor l Results:

See Executive Summar i

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9311180142 931025 i PDR ADOCK 05000317 54 i G PDR g '

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EXECUTIVE SUMMARY Calvert Cliffs Nuclear Power Plant. Units 1 and 2 Inspection Report Nos. 50-317/93-28 and 50-318/93-28 Plant Operations: (Operational Safety Inspection Module 71707, Prompt Onsite Response to Events at Operating Power Reactors Module 93702) The Valve Re-labeling Project was i providing a high quality enhancement to plant safety and ef6ciency. The Event-Free Operations Program has demonstrated measurable success in reducing the severity and frequency of operator-induced events. Operations department self-assessment efforts were providing meaningful input to safe plant operation and were an effective management too The 11 emergency diesel generator systems and the Unit 2 service water system were in good material conditio Maintenance: (Maintenance Observations Module 62703, Surveillance Observations Module 61726) The demineralized water storage tank partially collapsed when a vacuum was inadvertently drawn on the tank during maintenance. BG&E's root cause investigation was still in progress at the end of the perio Encineerine: (Module 71707) An Unresolved Item concerning potential weaknesses in BG&E's corrective action process, interdepartmental communications, and system design was identified following a leak from the Unit I service water syste Plant Suonort: (Module 71707) The Operating Experience Review Unit continued to be a notable strength in BG&E's self-assessment process, though management response to the unit's Endings and recommendations was not always prompt or effective. High quality technical procedures were being produced ahead of schedule by the Procedures Upgrade Project.

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SUMMARY OF FACILITY ACTIVITIES Both units operated at power without significant incident throughout the perio ,

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' PLANT OPERATIONS

. Ocerational Safety Verification i

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 i

-- primary auxiliary building - protected area fence

- radiological control point - intake structure  :

-- electrical switchgear rooms -- diesel generator rooms

- auxiliary feedwater pump rooms -- turbine building j Control room instruments and plant computer indications were observed for correlation between channels and for conformance with technical specification (TS) requirement .;

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 procedure 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 _i were reviewed for unexpected changes. Logs 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. The inspectors also examined the condition of meteorological and seismic monitoring system 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 .

In addition to normal utility working hours, the review of plant operations was conducted during backshifts (evening shifts) and deep backshifts (weekend and midnight shifts).

Extended coverage was provided for 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> during backshifts and 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> during deep backshifts. Operators were alert and displayed no signs ofinattention to duty or fatigu 'fhe inspectors observed an acceptable level of performance during the inspection tours detailed abov !

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2  ; Followup of Events Occurring During Insnection Period

There were no significant operational events during the perio l Plant Operations and Safety Review Committee

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The inspectors attended several Plant Operations and Safety Review Committee (POSRC) -

meetings. TS 6.5.1 requirements for member attendance were verified. The meeting  ;

agendas included safety significant issue reports, proposed tests that affected nuclear safety, j 10 CFR 50.59 evaluations, reportable events, and proposed changes to plant equipment that ;

affected nuclear safety. Overall, the level of review and member participation was !

satisfactory in fulfilling the POSRC responsibilitie .4 Valve Re-labelling Project

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Inspectors reviewed the operations department valve re-labelling project. Preparation for the i project began in July 1992 and actual work began in January 1993. The project scope i

encompassed all of the approximately 31,000 valves in the plant. Currently, about 20% of the new labels have been installed. The new labels were color-coded and bar-coded lexan, ,

except for the labels in the containment which were environmentally qualified, porcelain !

covered, stainless steel. These replaced older style embossed aluminum label !

i Concurrent with re-labelling, the project was conducting system walkdowns to verify as-built ,

configurations with prints, enhancing the noun descriptions of valves for instructions and procedures, and inputting valve data to the site computer system. The project is expected to [

be completed in July 1995. Inspectors discussed the new labels with operators, conducted ;

spot checks of completed re-labelling, and assessed that it was of very high quality. The :

new labels were much easier to read, provided more complete valve descriptions, and l minimized the risk of confusion between similar valves or units. Inspectors assessed the- j project to be a good management initiative that was providing a high quality enhancement to ;

plant safety and efficienc j Event-Free Operations Program  !

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Inspectors reviewed BG&E's Event-Free Operations Program, an initiative begun in 1989 to i

reduce the frequency and severity of operations-caused events. At that time, BG&E averaged one significant event every 28 days. During the current SALP period, BG&E r averaged one significant event per 91 days, a three-fold improvement and substantially ahead i of their goal of one per 60 day !

i The review consisted of a survey of events that occurred during the SALP period taken from !

BG&E issue reports and previous NRC inspection reports, and a series of interviews l conducted with site operators and managers. In addition, BG&E gave the mspectors a j l

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detailed presentation on the program and discussed their perception of improved  ;

performanc While primarily an operations department initiative, support departments contributed to the '

program. The program focused on the consistent use of several practices and philosophies, including:  ;

• adherence to procedures, including the expectation to understand the procedure rather than blind compliance;

• good communications, including appropriate repeat-back of instructions; i

e self-verification and maintaining a questioning attitude;

• good watch turnover, including pre-shift and pre-evolution briefing The operations department developed a detailed set of criteria to define significant events in the areas of nuclear safety, radiological events, personnel safety, electrical generation, external perception, and cost. The program was tracked using a detailed set of performance .

indicators and an aggressive department self-assessment program. Based on a review of the criteria and previous independent inspection, inspectors found that BG&E had a very low l

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threshold for event classification, which tended toward conservatism and safety consciousnes Inspectors reviewed events from the current SALP period and found that operator induced l events generally occurred near the end of refueling outages, during periods of extensive !

system testing in preparation for a mode change. Three reactor coolant system overfill events occurred in July 1992, following Unit l's refueling outage, and three unrelated events i occurred in June / July 1993, following Unit 2's refueling outage. These events were documented in NRC Inspection Reports 50-317 and 318/92-19,93-16, and 93-23. BG&E ,

had noted this trend and believed that the apparent cause for these events was an outage mode versus an operating mode mentality coincident with the high level of activities associated with restoring the plant to operation. BG&E is evaluating possible enhancements :

to strengthen the program for the upcoming February 1994 outag '

Despite the end-of-outage events, the inspectors concluded that the Event-Free Operations Program has been generally successful in reducing both the severity and frequency of operator-induced events. The program has been aggressively supported by management and has demonstrated measurable succes ] Performance Assessment Initiatives for Operations l

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During the period, the inspectors reviewed operations department self-assessment effort BG&E has implemented several initiatives to provide critical self-assessment of all facets of

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plant operations. BG&E described these initiatives in Operations Administrative Policy (OAP) 91-8, " Operations Self-Assessment Plan." The supervisory observation progrtm was j the center piece of the plan. This involved senior reactor operator licensed personnel ,

performing two to four hour observations in areas of their own choosing, completing a total of about 14 such observations each month. Operations management formally documented, reviewed, and trended the results as performance indicators. Other elements of the plan

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included quality observations by individuals not directly asse iated with plant operations, internal audits, safety tagging surveillances, and shutdown safety surveillance The inspectors reviewed samples of documented results of supervisory and quality observations, internal audits, and safety tagging surveillances. In general, they were of good quality and well-focused in pertinent areas of operations. Observers made good use of the remarks section of the checklists to note problems and recommend possible corrective actions. When appropriate, supervisors highlia.,hted positive observations. The inspectors noted that operations management utilized both positive and negative observations to reinforce and reiterate their expectations regarding event-free operations. The inspectors concluded that this program provided meaningful input to safe plant operation and provided a means by which operations management could assess the effectiveness of their policies and procedure .7 Engineered Safety Features System Walkdown In addition to routine observations made during regular plant tours, the inspectors conducted walkdowns of the accessible portions of selected safety systems. The inspectors verified'

system operability through review of valve lineups, control room system prints, equipment conditions, instrument calibrations, surveillance test frequencies and results, and control room indications. The inspectors performed walkdowns of the following systems during the inspection period: ,

i I1 Emergency Diesel Generator (EDG) and Auxiliaries The inspectors found the 11 EDG and its associated support systems (fuel oil, starting air, lube oil, cooling water) properly aligned for standby / automatic operation. BG&E had maintained the diesel and support equipment in very good material condition. The inspectors did not identify any unacceptable condition Unit 2 Service Water System inspectors walked down safety-relatxl portions of the Unit 2 service water system. No discrepancies were noted in the valve lineup, and the system was in good material conditio ;

Some minor administrative deficiencies in the valve lineup sheets were identified by the inspectors, which BG&E took appropriate actions to correc :

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. MAINTENANCE j

Maintenance Observation l

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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 skilis of the i'

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activities were accomplished by qualified personnel; [

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where necessary, radiological and fire preventive controls were adequate and implernented;

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quality verification hold points were established where rei aired and observed; and

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equipment was properly tested and returne<l to servic !

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Maintenance activities reviewed included:

i MO 29201515 Double nut 21 emergency diesel generator (EDG) speed switch  !

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.l MO 29203314 Install new service water vent valves 1 9 MO 29302502 Overhaul 21 EDG moisture separators I MO 29304966 Overhaul 21 EDG air start check valves i

- MO 29303525 Remove spool piece downstream 2-SW-115/108  !

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M's 29302161 Clean 22 SRWHX tubes .[

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MO 29302182 Clean 22 CCHX tubes MO 29303930 Boroscope inspection of 22 SW header  !

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MO 29206116 Inspect / lube 23 CC pump coup!ing  !

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MO 09200762 Rig and install cask platform for SFP project , ,

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I MO 09301993 Perform ETPs 93-11 & 12 for the ISFSI mockups to validate the j

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content of fuel handling procedures FH -50 & 51

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MO 19302719 Perform SRWHX-02 procedure on 11 service water heat exchanger .

(tube cleaning)

MO 19302723 Inspect and clean 11 emergency core cooling system duplex strainer !

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MO 19302737 Inspect and clean 11 component cooling water heat exchanger tubes j

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MO 19305592 Reset 11 cmergency diesel generator underfrequency relay 1 MO 19207353 11 high pressure safety injection pump oil sampling l

The work observed was performed safely and in accordance with proper procedure Inspectors noted that an appropriate level of supervisory attention was given to the work depending on its priority and difficult .2 Surveillance Observation i

The inspectors witnessed / reviewed selected surveillance tests to determine whether properly 4 approved procedures were in use, details were adequate, test instrumentation was properly i calibrated and used, technical specifications were satisfied, testing was performed by !

qualified personnel, and test results satisfied acceptance criteria or were properly .!

dispositione l

The following surveillance testing activities were reviewed: ,

STP O-8B-2 21 EDG and 4kV bus 24 LOCI Sequencer Test

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STP O-8-2 21 Diesel Generator Test >

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The surveillance testing was performed safely and in accordance with proper procedure Inspectors noted that an appropriate level of supervisory attention was given to the testing - ,

depending on its sensitivity and difficult !

! Erial Collaose of Water Storage Tank -}

l On September 27, the demineralized water storage tank (DWST) partially collapsed when a 3 vacuum was inadvertently drawn on the tank. Maintenance workers had removed both of the !

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vacuum breakers on the tank for overhaul and covered the openings to prevent foreign !

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material intrusion. Coincidently, water was being transferred from the tank. As a result, a ;

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vacuum was drawn which partially collapsed the tank. The partial collapse caused two major 4 depressions in the tank, the largest of which was approximately 4.5 feet deep. There was no ;

apparent damage to any welds, and no leaks were detecte l The DWST was a stainless steel, vertical, cylindrical tank with a capacity of 350,000 gallons. It provided makeup water for many systems, including the reactor coolant, ,

condensate, service water, and component cooling water systems. There was no seismic design requirement for the tank. It was not safety-related, and alternative sources of water were availabic if required to shutdown and cooldown the reactor BG&E performed an engineering evaluation to justify the continued use of the DWST. It concluded that the tank was acceptable for continued use, provided that restrictions were placed on the allowable water level in the tank.

i BG&E was conducting a roct cause investigation of the event as the period ended, and was f making preparations to repair the tank. The results of the investigation will be evaluated by [

the NR * ENGINEEI'iNG The inspectors reviewed selected design changes and modifications made to ti:e facility which

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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, l Plant Operations Review Committee approval, procedural controls, post-modification testing, ;

procedure changes resulting from this modification, operator training, and USFAR and ,

drawing revisions. The following activities were reviewed:

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. Excessive Service Water System Leakage On September 29,1993, BG&E removed the 11 service water (SRW) train from service ,

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following the discovery of excessive system leakage. The leak rate was about 26 gpm from one ruptured heat exchanger tube. The service water system was a closed loop system that !

provided cooling to the emergency diesel generators (EDGs), the containment air coolers and l

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the spent fuel pool heat exchangers, among other systems. It had no seismically qualified

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- source of makeup water, but it was required to remain operable throughout a plant event to support the EDG';. The duration of a plant event was defined by the Updated Final Safety Analysis Report (USFAR) to be 30 days. BG&E's calculations showed that, with normal .

system leakage of 2 gpm and no makeup water, net positive suction head to the SRW pumps could be lost in 13 %us and with a leak rate of approximately 17 gpm and no makeup, in l about an hour and a hal v

During their initial review of the event, the inspectors identified several issues. These ;

included weaknesses in BG&E's corrective action process, weakness in interdepartmental ;

communications, and potential design deficiencies. These issues were Unresolved as the L

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period ended (URI 50-317 and 318/93-28-01). NRC review of these issues will be '

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documented in a future inspectio ' PLANT SUPPORT Radiolocical 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 of and compliance with special work permits (SWPs) were reviewed to ensure detailed descriptions ,

of radiological conditions were provided and that personnel adhered to SWP requirement !

The inspectors observed that controls of access to various radiologically controlled areas and l

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use of personnel monitors and frisking methods upon exit from these areas were adequat 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 !

licensee procedure :

Health Physics technician control and monitoring of these activities were determined to be i good. Overall, a satisfactory level of performance was observe : Emercency Preparedness

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The inspectors toured the onsite emergency response facilities to verify that these facilities 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 l findings in this are Inspectors observed portions of a site emergency preparedness drill on September 23. The ;

scenario involved a containment breach followed by a loss of coolant accident coincident with ,

loss of the emergency core cooling system. No outside agencies were involved in the dril j No unacceptable conditions were observe !

' Security

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During routine inspection tours, the inspectors observed implementation of portions of the ;

security plan. Areas observed included access point search equipment operation, condition of 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. No unacceptable conditions were identifie i 5A Plant Chemistry The inspectors verified that primary and selected secondary water chemistry were maintained

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within technical specification and procedural limits. In addition, they reviewed secondary

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water activity analysis and radiation monitor alarm status to confirm steam generator tube integrity. The inspectors also examined analysis trending data to determine if appropriate action was being implemented to restore plant chemistry to normal values. There were no

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unacceptable cordeions identifie ! Fire Protection j

During plant tours, the inspectors assessed plant areas for fire hazards including ignition ,

sources and flammable materials. They also examined fire alarms, extinguishing equipment, 1 emergency lighting, actuating controls, fire fighting equipment, and fire barriers for operability. In addition, the inspectors verified that required compensatory measures, such '

as fire patrols, were properly implemente .6 Housekeeping *

The inspectors assessed the control of plant housekeeping in safety related areas. They also

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examined these areas for potential missile hazards such as gas cylinders that could damage safety significant equipment. General plant housekeeping during the period was goo ; Operating Experience Review Unit

The inspectors conducted a review of the Operating Experience Review Unit (OER), which !

functioned as the site independent safety engineering group. OER was responsible for the ongoing independent evaluation of activities performed at, or in support of, Calvert _ Cliffs -

that may have an effect on nuclear safety. OER was divided into three grcups: the independent safety evaluation unit (ISEU), which generally identified and reviewed trends that might challenge nuclear safety; the plant operating experience review unit (POER), -

which generally performed root cause analyses of plant events; and the industry operating l experience review unit (IOER), which generally evaluated industry events for applicability to l Calvert Cliff l BG&E formed the OER in 1989 and currently has a staff of 16, including 6 engineers and 6 field analysts. The personnel were chosen to provide a diversity of experience and background, and are moved within the three OER groups as necessary to conduct  !

evaluations. The staff have all received formal training in investigative techniques, root-cause analysis, and human performance evaluation processe ,

OER conducted or participated in event investigations as specified in Calvert Cliffs Administrative Procedure QIe2-101, " Event Investigation and Poot Cause Analyses." QIe2-101 defined the event classification at Calvert Cliffs from Priority 1 to 3, from most to least severe. OER participated in investigations of all Priority 1 or 2 events and in events of recurring nature. They also participated in some investigations at the request of the general supervisors or direct-report supervisors. OER conducted approximately a dozen event j j

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investigations last year, almost none of which were requested by these supervisors, and about i 15 this year, about half of which were requested. OER routinely did little or no review of ,

proposed plant modifications or changes, ualess implementation prablems occurre i The Supervisor-OER reported to the Manager-Nuclear Safety and Planning Department, who

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reported to the Vice President-Nuclear Energy Division (VP-NED). The OER customers l

were, in fact, the Plant General Manager (PGM) and the VP-NED. The PGM also empowered the OER's recommendations, when required. OER products were documented in Observatica Reports, Evaluation Reports, Quarterly Trend Reports, Industry Events l Newsletters, and an Annual Nuclear Safety Evaluation Repor .;

Inspectors discussed OER with BG&E senior site and corporate management, including the i PGM, VP-NED and the Senior Vice President-Generation. They considered-the OER to be - ---

an invaluable tool for evaluating plant safety and for providing indicators for allocating resources to weak areas. Nevertheless, inspectors found that response to OER findings and 3 recommendations was not always prompt or effective. Recent examples of weak response to .

OER findings concern NDE, welding, and foreign material exclusion issues. BG&E has- [

recognized this deficiency and was developing changes to strengthen the syste j

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Inspectors routinely reviewed event investigations and OER reports and have generally found them to be exceptionally strong, characterized by comprehensiveness, depth, and i forthrightness. Recent examples of excellent event investigations included a Unit I trip due -

to a main generator ground fault, a dual unit trip following a partial loss of offsite power, l

and a reactor vessel head penetration leak. The Annual Nuclear Safety Evaluation Reports have also been notably strong and critica ;

During the Integrated Performance Assessment Team inspection in December 1991 (NRC

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Inspection Report 50-317 and 318/91-82), the NRC assessed the OER to be a notable strength of BG&E's self-assessment. Inspectors concluded that OER's performance was still a notable strengt ;

! Procedures Uoerade Proeram Uodate

In 1989, BG&E initiated a program to improve the quality of the technical and administrative . !

procedures. The goal of the program was to develop appropriately detailed, consistent, and  :

accurate procedures. BG&E called the effort the Procedures Upgrade Program (PUP). The j inspectors conducted a review of the PUP to ascertain the progress of the project and to

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I assess the procedure quality with regard to the technical procedure l R

BG&E has made significant progress in upgrading their technical procedures. In December 1992, BG&E completed the upgrades to procedures designated as " Priority 1." These included all surveillance test procedures, emergency operating procedures, and abnormal operating procedures. They have also completed the majority of the remaining technical -

procedures. As of October 8,1993, only a small percentage of technical procedures still had

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not been upgraded. Most of these procedures were system operating instructions, ,

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annunciator procedures, and non-destructive examination procedures. BG&E informed the t

inspectors that these procedure upgrades would be completed by June 1994, six months ahead of the PUP schedul !

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The inspectors reviewed selected upgraded procedures and found that procedures were of high quality. The procedures were consistent with the appropriate writers guide and .

incorporated human factors considerations. BG&E trended PUP procedures deficiencie ;

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The inspectors noted that the number ofidentified deficiencies was very low and was trending downwar ,

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In conclusion, BG&E has made significant progress in upgrading their technical procedure The completion of the remaining technical procedure upgrades was six months ahead of schedule. The upgraded procedures were of high qualit .0 M ANAGEMENT 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. The licensee acknowledged the ,

inspectors findings. No written material was given to the licensee and no proprietary '

information related to this inspection was identifie .1 Preliminarv Inspection Findings >

An Unresolved Item concerning potential weaknesses in BG&E's corrective action process, i

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interdepartmental communications, and system design was identified following a leak from the Unit I service water system. The issue is documented in section 't

Attendance at Management Meetings Conducted by Region Based Inspectors l

Inspection Reporting i Date Subject Report N Inspector l i

10/1/1993 Security 50-317/93-29 R. Albert ,

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50-318/93-29 t

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