IR 05000317/1997005
| ML20217J294 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/09/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20217J285 | List: |
| References | |
| 50-317-97-05, 50-317-97-5, 50-318-97-05, 50-318-97-5, NUDOCS 9710210028 | |
| Download: ML20217J294 (19) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
License Nos.
DPR 53/DPR-69 Report Nos.
50 317/97-05; 50-318/97-05 Licensee:
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 Dates:
July 27,1997 through September 13,1997 Inspectors:
J. Scott Stewart, Senior Resident inspector Fred L. Bower 111, Resident inspector Henry K. Lathrop, Resident inspector Suresh Chaudhary, Senior Reactor Engineer, RI Approved by:
Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects 9710210028 971009 DR ADOCK 050003 7
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EXECUTIVE SUMMARY Calvert Cliffs Nuclear Power Plant, Units 1 and 2
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Inspection Report Nos. 50 317/97 05 and 50 318/97-05 This integrated inspection report includes aspects of BGE operations, maintenance,
engineering, and plant support. The report covers a seven week period of resident inspection and includes the results of an announced inspection by an engineering
specialist.
Mant Operations An influx of jellyfish fouled the Unit 1 intake traveling screens and resulted in the failure of the shear pin in the 16B traveling screen. Operators secured the a circulating water pump and initiated a rapid power reduction to maintain the main condenser differential temperature within specification. The operators properly responded to this event, used
procedures appropriately, and controlled the transient with a high regard for reactor safety.
The inspectors observed that a pre-evolution br.efing for auxiliary feedwater pump surveillance testing included allinvolved personnel and a discussion of test performance and communications. The reactor operator in charge of the evolution conducted the briefing. The inspectors observed that an involved senior reactor operator provided a discussion of weaknesses identified in previously conducted auxiliary feedwater pump performance testing. The testing was performed in accordance with the procedure and
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good three way communications were observed. The inspectors considered the inclusion of previous performance problems in the briefing for the testing to be a strength and found that the testing was effectively completed.
Control room operators completed a reactor shutdown and cooldown in preparation for a reactor coolant pump seal replacement. Prior to the actual shutdown, the operating crew completed training for the shutdown on the plant simulator. The shutdown was conducted using three-point communications, self-checking techniques, and peer verifications of a
control manipulations. The inspectors concluded that the shutdown and cooldown were safely conducted.
Maintenance Maintenance was conducted safely and in accordance with approved procedures. Workers -
were knowledgeable and performed work effectively.
The maintenance department completed a root cause evaluation for a compression fitting
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that failed in service. The fitting had been assembled without a detailed procedure during the 1996 refueling outage. The root cause evaluation identified that corrective actions for prior compression fitting problems were inadequate. The inspectors found that BGE's evaluation and root cause analysis of this event was thorough and self-critical. A Notice of Violation was issued for failure to complete corrective actions for previous compression-fitting problems.
Surveillance testing was performed safely and in accordance with proper procedures. Pre-test briefings appropriately included means of communications, test control details, and contingency actions. Procedures were detailed and facilitated interpretation of test results.
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Executive Summary (cont'd)
The inspectors noted that an appropriate level of supervisory attention was given to observed testing depending on its sensitivity and difficulty.
Enaineerina BGE received a 10 CFR Part 21 report from ABB Combustion Engineering and took immediate ection to ensure tia' the reactors maintained a specified margin of safely. The inspectors considered the BGC.,ctions in response to the Combustion Engineering Part 21 report to be prompt and appropriate.
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Engineering personnel were actively involved in oversight and trending of the 11B reactor coolant pump seal performance. The daily evaluation of the reactor coolant pump seal l
degradation and communications with the operations department were considered very I
good.
Nuclear Fuels Management (NFM) engineers effectively determined the optimum control rod positions to minimize the axial symmetry index (ASI) transient for the reactor coolant pump seal shutdown. Also, the feedwater system operated in automatic mode throughout the shutdown, indicating that engineering support and corrective actions for previous problems with the system have been effective. Both fuels management and feedwater system engineers were in the control room during the reactor shutdown. The shutdown was accomplished without any reactor control problems.
The operations and engineering departments implemented multiple detailed on-line safety.
risk assessments for planned maintenance and maintenance related equipment outages.
These assessments effectively supported equipment outages by ensuring that redundant safety systems were available so that the overall plant risk was minimized.
Plant Suppo_r1 BGE instituted a briefing checklist that had been developed as part of the corrective actions for recent radiation controls problems. The briefing enhancements were considerad a good initiative to ensure the effectiveness of radiation control work preparation.
BGE has adopted a testing and maintenance process for the emergency lighting units that allowed the units to remain in operation until they failed. A verification of emergency
. lighting capability was not performed when lighting units were determined to be inoperable.
BGE had generic problems with emergency lighting units and insufficient corrective actions led to continuing failures of the tested emergency lighting fixtures.
Safety Assessment / Quality Verification A root cause evaluation for compression fitting problems was through and self-critical, iii
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TABLE OF CONTENTS EX E CUTIV E S U M M ARY............................................. il T A B L E O F C O NTE NT S.............................................. iv Summ ary of Pla nt Statu s............................................ 1
' l. O p e r a tio n s..................................................... 1
Conduct of Operations.................................... 1 01.1 General Comments
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11. Maintenance -
.................................................. 3 M1 Conduct of Maintenance
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M1.1 General Comments
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M1.2 Emergency Lighting Maintenance Order Review..........
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M1.3 Routine Surveillance Observations....................... 5 M7 Quality Assurance in Maintenance Activities
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M7.1 (Closed) LER 5 0 317 /9 7-00 5.......................... 5 IE. Engineering
................................................... 7 E1 Conduct of Engineering
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E1.1 Combustion Engineering 10 CFR Part 21 Report............. 7 E8 Miscellaneous Engineering issues............................ 8 E8.1 Surveillance of Tendons in Unit 1 Containment
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I V. Pl a n t S u p p o rt.................................................. 9 R1 Radiological Protection and Chemistry (RP&C) Controls............. 9 F2 Status of Fire Protection Facilities and Equipment................ 10 F2.1 Emergency Lighting Followup
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F8 Miscellaneous Fire Protection issues......................... 12 F8,1 Ma'n Control Room Fire Suppression Review.............. 12 V. Management Me eting s........................................... 13 X1 Exit Meeting Summary................................... 13 X2 Review of UFS AR Commitments............................ 13 j
ATTACHMENT Attachment 1:
Partial List of Persons Contacted Inspection Procedures Used items Opened, Closed and Discussed List of Acronyms Used iv i
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ReDort Details Summarv of Plant Status Unit 1 began the inspection report period at full power. Power was reduced to approximately 89 percent on August 6 for planned maintenance. Power was reduced to 90 percent for approximately four hours on August 18 due to clogging of the intake system by jellyfish (See below). Unit 1 was shutdown on September 12 to facilitate repairs to the 11B reactor coolant pump seal.
Unit 2 remained at full power fnr the inspection period with exception of a brief power reduction to 86 percent on August 23 for planned maintenance.
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1. Operations
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Conduct of Operations 01.1 General Comments (71707)
Overall plant operations were cenducted safely vnh a proper focus on continued nuclear safety. Using Inspection Procedure 7170/, " Plant Operations," the inspectors conducted frequent reviews of ongoing plant operations, in general, the conduct of operations was professional and safety-conscious. The operations and engineering departments implemented multiple detailed on-line safety risk assessments for planned maintenance and maintenance related equipment outages.
The applicable system Technical Specification (TS) limiting conditions for operation (LCO) were entered and exited correctly for the equipment outage times. The control room was maintained free of distractions and operators remained cognizant of plant conditions. Control room deficiencies were promptly identified and issue reports were written to initiate corrective actions. The operators used the plant computer to prompt them of changing plant conditions prior to receipt of control board alarms. During the inspection period, operations and engineering department personnel routinely evaluated the effectiveness of the 11B reactor coolant pump seal and used predictive engineering to assure that plant operations could continue until a planned outage date. Engineering oversight and involvement in the data gathering, trending and evaluation of the reactor coolant pump seal degradation were considered very good.
On August 19, an influx of jellyfish fouled the Unit 1 intake traveling screens and resulted in the failure of the shear pin in the 16B traveling screen. Operators
secured the 16 circulating water pump and initiated a rapid power reduction to maintain the main condenser differential temperature within Maryland State discharge permit specifications. Reactor power was stabilized at 89 percent to clear the fouling, replace the shear pin, and restart the circulating water pump. The reactor was restored to full power later that day. The inspectors observed portions of the plant power changes and discussed the transient with operators. The inspectors concluded that the operators properly responded to this event, used procedures appropriately, and controlled the transient with a high regard for reactor safet.
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The inspectors observed the pre-evolution briefing and performance of auxiliary feedwater pump surveillance testing by operations personnel on September 12. The briefing appropriately included allinvolved personnel and a discussion of test performance and communications was included.. The reactor operator in charge of the evolution conducted the briefing. A prepared briefing checklist was completed during the briefing and ensured that allimportant aspects of the evolution were covered. The inspectors observed that an involved senior reactor operator provided a discussion of weaknesses identified in previously conducted auxiliary feedwater pump performance testing. The testing was performed in accordance with the procedure and good three way communications were observed. The test was completed satisfactorily. The inspectors considered the inclusion of previous performance problems in the briefing for the testing to be a strength and found that the testing was effectively completed.
On September 12, the inspectors observed control room operations during the Unit 1 shutdown and the subsequent cooldown in preparation for a planned outage to replace the 118 reactor coolant pump seal. Nuclear Fuels Management (NFM)
engineers planned for the shutdown by determining the optimum control rod positions to minimize the axial symmetry index (ASI) transient during the shutdown.
Prior to the evolution, the operating crew practiced for the shutdown on the plant simulator using the NFM strategy. Operations management also scheduled six operator license applicants trainees to obtain significant manipulations of the controls during the shutdown. The shutdown was safely conducted by the operators through the use of three-point communications, self-checking techniques, and peer verifications of control manipulations. Feedwater system and fuels management engineers were present in the control room during the evolution. At 10 percent reactor power increments, the trainees rotated through the primary
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(control rod and chemical control) and secondary (main turbine generator) control stations during the shutdown. NFM engineers and the digital feedwater system engineer provided good support to operations during the shutdown. Minor deviations from the NFM shutdown strategy were reviewed and understood. The General Supervisor-Nuclear Plant Operations provided management oversight and crew observation. Nuclear Performance Assessment Department also performed an independent assessment of the shutdown operations. The feedwater system operated in automatic mode throughout the shutdown, indicating that engineering support and conective actions for previous problems with the system have been effective. The inspectors concluded that the shutdown and cooldown for the Unit 1 planned outage were safely conducte _ _ _ _ _ _ _ _ _ _ _ _ _ - _.
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II. Maintenancg M1 Conduct of Maintenance M1.1 General Comments s
a.
Insoection Scooe (62707)
The inspectors reviewed BGE maintenance daily and followed the status of work that involved technical specifications or affected safety systems. Component failures or system problems that affected systems included in the BGE maintenance rule program were assessed to determine if the maintenance was effective. Also, the inspectors directly observed all or portions of the following work activities:
MO2199700592 Clean 22 Service Water Heat Exchanger and Inspect Anodes M01199601355 Remove Unit 1 Channel Deviation Comparator Averager M01199703979 Replace Flow Tube on Containment Radiation Monitor MO2199604795 Replace 22 Saltwater Pump with Spare Pump MO1199701355 Inspect Trip Circuit Breaker No.6 l
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Observations and Findinas The inspectors found that the selected maintenance activities were performed safely and in accordance with approved procedures. The inspectors verified tb t selected system ad component failures were evaluated and outage time was iNiuded in the BGE maintenance rule program. BGE report cards detailed problems and how these problems affected system function. As applicable, appropriate radiological precautions and controls were implemented during maintenance. The inspectors neted that an appropriate level of supervisory attention was given to work depending on its priority and difficulty. Techniciars were experienced and knowledgeable of their assigned duties. The inspectors frequcotly observed system and design engineers and quality control personnel monitoring job progress. Also, quality control personnel were present whenever required by procedure.
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M1.2 Emeraenev Liahtina Maintenance Order Review The inspectors also reviewed or observed the following sample of maintenance work orders (MOs):
MOO 199601643 Emergency Lighting 8-hour Operational Test MOO 199601514 Emergency Lighting 8-hour Operational Test MOO 199600723 Emergency Lighting 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Operational Test MOO 199502929 Emergency Lighting 8-hour Operational Test MOO 199502928 Emergency Lighting 8-hour Operational Test MO219S605047 Emergency Lighting Quarterly Operational Test MO2199700311 Emergency Lighting Omrterly Operational Test MO2199700310 Emergency Lighting Quaerly Operational Test MO2199605046 Emergency Lighting Quarte.ly Operational Test MO2199601643 Emergency Lighting Quarterly Operational Test MO1199700768 Emergency Lighting Quarterly Operational Test M01199606424 Fmergency Lighting Quarterly Operational Test M01199605096 Emergency Lighting Quarterly Operational Test The inspectors noted that the documentation of actions taken were not sufficiently detailed to provide a maintenance history. Although the maintenance orders documented the emergency lighting units worked and the numbers of parts used for repairs, the action taken narratives did not link the specific emergency lighting units to the parts used and the repairs made.
The inspectors found that except for the control room emergency lighting sys'.e'n, the emergency lighting was not included within the scope of the BGE mainter.ance rule program. The emergency lighting cystem is used in safe shutdown of the plant under some conditions, and its inclusion within the maintenance rule program scope is unresolved pending further NRC review (URI 50 317&318/97 05-01). At the end of the inspection period, BGE informed the inspectors that an expert panel was
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being assembled to review inclusion of a number of systems, including emergency
lighting, in the maintenance rule program. Additional concerns related to the testing, f ailure rate, and corrective actions for emergency lighting units were documented in section F2.1 of this report, c.
Conclusions on Conduct of Maintenance in general, maintenance was conducted safety ai.d in accordance with approved procedures. Workers were knowledgeable and performed work effectively. Work orders used to make repairs to emergency lighting units had not been marked in sufficient detail to determine what parts and repairs were made to which lighting units. Also, BGE had not included emergency lights in the maintenance rule program. Similar problems were not observed in the other maintenance activities.
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M1.3 Routine Surveillance Observations a.
Insoection Scoce (61726)
The inspectors observed and reviewed selected surveillance tests to determine whether approved procedures were in use, procedure 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 dispositioned. Surveillance testing activities that were inspected included:
STP O 73C 2 Component Cooling Pump Quarterly Test STP-O-88 1 Test of 1B DG and 14 4Kv Bus LOCl Sequencer STP-O-7312 HPSI Pump and Check Valve Quarter y Test STP-O 8A-1 Test of 1 A DG and 114Kv Bus LOCl Sequencer STP O 73A-1 Saltwater Pump and Valve Operability Test STP-0 73K-2 Containment Spray Pump Operability Test b.
Observations a4Findinas The observed surveillance testing was performed safely and in accordance with approved procedu es. Pre test briefings appropriately included means of communications, test control details, and contingency actions. Participants in the testing were knoveledgeable and followed the instructions provided at the briefings.
Workers and operators used effective communications and problems, when identified, were documented on the test record and issue reports were written to initiate repairs. The inspectors noted that an appropriate level of supervisory attention was given to the testing depending on its sensitivity and difficulty.
Quality assurance personnel were seen observing some of the surveillance activities, c.
Conclusions on the Conduct of Surveillance Activities Surveil!ance activities were effectively conducted using approved procedures.
Supervisory involvement with surveillances was appropriate and quality assurance personnel effectively monitored some surveillance performance. Test problems were appropriately documented and dispositioned.
M7 Quality Assurance in Maintenance Activities M7.1 IQesed) LER 50-317/97-005 Reactor Coolant System Leak Due to Failed Comoression Fittina a.
Scope (97902)
The inspectors reviewed a Licensee Event Report (LER) that described plant and operator response to a Unit 1 Reactor Coolant System (RCS) leak of approximately 810 gallons per minute that occurred on May 29,1997. Following the event, BGE
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completed a detailed root cause investigation and implemented a number of corrective actions. The inspectors reviewed the root cause and observed some nf the specified corrective actions, b.
Observations and Findinas A rapid plant shutdown was completed in response to a RCS leak that occurred on May 29,1997. This event was previously documented in NRC Inspection Report 50 317/97 03. BGE subsequently determined that the leakage source was a failed 3/4 inch compression fitting in an instrument line from the pressurizer. The instrument tubing had pulled completely from the elbow while the ferrule and nut remained with the fitting. BGE found that the cause of the compression fitting failure was the insufficient compression of the ferrule that resulted from improper assembly. BGE concluded that the tubing was fully inserted into the fitting; however, the nut was not sufficiently advanced to compress the ferrule. The failed RCS compression fitting was assembled during the 1996 refueling outage without detailed procedures.
BGE determined that inadequate maintenance practices including: failure to perform
"go/no-go" gauge checks and failure to perform adequate post-swaging inspection of compression fittings had potential generic implications. After the event, BGE l
inspected approximately 600 " critical" compression fittings on high pressure l
systems that could have a significant impact on the plant if they failed.
Approximately half of the fittings inspected required some adjustment.
The BGE corrective actions included: (1) expanding the scope of compression fitting inspections beyond critical fittings on a case basis during scheduled f
maintenance windows; and, (2) limiting compression fitting work to essential repairs while providing additional controls and oversight until the completion of the root cause analysis and completion of corrective actions.
The inspectors reviewed the root cause analysis. The analysis included: (1)-
background information, (2) an event description, (3) evaluation of safety significance and effects on site goals, (4) generic implications, (5) review of similar events, (6) identification of problems identified, (7) causal analysis, and (8)
recommended corrective actions with scheduled due dates. BGE conc'aded that a generic problem with compression fittings had been identified via numerous issue reports and operating experiences. BGE also concluded that insufficient priority or emphasis by management to resolve the on-going compression fitting problem led to the RCS leak incident.
The root cause analysis documented several missed opportunities that could have prevented the problems. Specifically, in 1992, BGE received and reviewed NRC Information Notice 92-15, " Failure of Primary System Compression Fitting." During 1992 and 1993, approximately 3000 fittings were inspected (1500 on each unit)
and 30 percent of the fittings required tightening to meet proper assembly requirements. Guidelines were developed to assist craft personnel in compression fitting work, but procedures were not developed and the guidelines were not
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7 required to be at the job site during fitting assembly. BGE issue reports written in 1992 described two fitting failures, including emergency diesel generator air start tubing that was found detached from its fitting and main generator hydraulic fluid found spraying from a loose compression fitting. As a result of a BGE issue report generated in 1993 concerning site and contractor personnel improper assembly of 45 of 50 inspected compression fittings, corrective action recommendations to develop a compression fitting assembly procedure and to provide training were made. Although, additional compression fitting problems occurred in 1995, as documented in issue reports, attempts to develop and implement appropriate procedures were not scheduled for completion until September 1997, In the root cause, BGE identified Giat the failure to ensure the effectiveness of corrective actions was an additional generic concern. BGE identified additional examples where industry experience and in-house experiences were evaluated, and recommendations were made but not effectively implemented included: (1) a 1996 loss of offsite power due to switchyard maintenance (NRC Inspection Report 50 318/96-02), and (2) a 1996 reversal of nuclear instrumentation leads (NRC IR
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l 50 317/96-06), The inspectors considered the failure of the pressurizer pressure I
instrument compression fitting for enforcement discretion in accordance with guidance provided in NRC Enforcement Guidance Memorandum 97 012A, The failure of the compression fitting was identified through a self-disclosing event that-could have been prevented based on prior opportunities identified in 1992,1993, with continuing problems in 1995. Because the problems continued through the period that included two years from the date of the compression fitting failure in 1997, enforcement discretion was not justified, c.
Conclusions BGE had identified a generic problem with compression fittings through industry information and numerous problems reported at Calvert Cliffs. At the time of the event, BGE corrective actions for this identified problem were inadequate, in that, insufficient priority and emphasis were placed on correcting the cause of compression fitting problems and an additional failure of a compression fitting in the reactor coolant system occurred BGE's failure to take timely and effective corrective actions for identified generic problems with compression fittings was a violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action (VIO 50 317&318/97-05-02). The inspectors found that BGE's evaluation and root cause analysis of this event was thorough and self-critical.
Ill. Enaineerina El Conduct of Enoineerina E1.1 Combustion Enaineerina 10 CFR Part 21 Reoort
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On August 14,1997, the NRC was informed by ABB Combustion Engineering Nuclear Systems of a 10 CFR Part 21 Report regarding an error in the energy i
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redistribution factor used in loss of coolant accident (LOCA) analyses. The inspectors reviewed the issue and informed BGE personnel of the concern. BGE informed the residents that they had been contacted by Combustion Engineering on July 11,1997 and at that time, had completed the actions recommended by the report. These actions included assuring that there was at least a two percent margin to the technical specification Fxy limit using excore detectors and a 0.2 kilowatts per foot margin between the measured plant linear heat generation rate and the heat generation rate limiting condition for operation using in-core detector signals (See Technical Specification 3/4.2). BGE regenerated the incore alarm data points and revised the appropriate procedure limits and requirements in the technical data book maintained in the Calvert Cliffs control room. BGE also initiated a review to determine if the reporting criteria specified in 10 CFR 50.46 i
had been met. At the end of the inspection period, BGE had determined that a 52 degree error in the peak clad temperature had existed; however, the required 2200 degree Fahrenheit limit would not have been exceeded prior to the protective margin adjustments. BGE initiated action to make a report to the NRC within 30 days of the determination. The inspectors considered the BGE actions to review the Combustion Engineering Part 21 prompt and appropriate.
E8 Miscellaneous Engineering issues E8,1 Surveillance of Tendons in Unit 1 Containment To assure the structuralintegrity of the containment, Calvert Cliffs Technical Specification (TS), Section 3.6.1.6, Amendment No. 212, for Unit 1 required that the integrity of the containment shall be demonstrated by a surveillance test of tendons every five years. These tests were performed on a representative sample of at least nine tendons selected (three each) from the three tendon groups (dome, vertical, and hoop). The tests consist of lift test of the tendon heads to determine the lift off load in the wires. Also one wire from each tendon group was removed for inspection to verify structural integrity and tensile strength. BGE inititiated testing of the Unit 1 containment during the inspection period.
During the current test, two vertical tendons indicated unacceptable lift off load, BGE then entered the action statement of technical specification 3.6.1.6, which required that the containment be evaluated by engineering within 90 days of the surveillance test. The low lift-off loads were determined to be due inadequate shimming during original ct,nstruction. The containment was verified operable by evaluating adjacent tendons. However, several other tendons indicated general and pitting corrosion and a number of broken tendon wires were observed. One tendon.
(34V11) had five broken wires. In view of these observations and to assure the integrity of the containment, BGE expanded the scope of the surveillance test to include 100% inspection (lift off and visual) of the vertical tendons for both containment structures.
The inspector witnessed the lifting operations for tendon No,34V13 in the Unit 1 -
containment structure. The setup of the lifting rig and the " lift-test" for this tendon was as specified in the surveillance procedure. The test was adequately covered by l
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engineering, quality assurance, and qualified test personnel. The inspector verified that the test gage was calibrated and tools were traceable.
At the end of the inspection period, the surveillance tests continued and were expected to take several weeks to complete. Engineering used preliminary evaluations to demonstrate the operability of the containment structures. At the end of the testing, BGE intended to verify the acceptability of the containment integrity, and determine if any further actions were warranted. The NRC will review the licensee's resolution of the tendon surveillance test concerns after the testing has been completed and the results evaluated by BGE. (IFl 50 317&318/97 05 03)
IV. Plant Sunoort i
R1 Radiological Protection and Chemistry (RP&C) Controls The inspectors observed a number of radiation controls briefings associated with high radiation area maintenance and operations tasks. The briefings were led by radiation controls personnel with the work group using a recently developed briefing checklist. Among the items covered in the briefings were evaluation of area dose rates, dosimetry requirements, the necessity of periodic dosimetry checks, worker self checking, contingency plans for radiation control problems, and proper coordination and communication between radiation controls personnel and the work (
group. The briefing checklist had been developed as part of the corrective actions for recent radiation controls problems. The briefing enhancements were considered a very good initiative to ensure the effectiveness of radiation control work preparation.
Because of problems in radiation controls, the radiation safety department implemented a number of program changes. Included was a change in radiation safety supervision, development and use of a number of high radiation area controls such as checklists, and general communication during site safety breaks regarding :
the need to improve radiation safety performance. The inspectors observed implementation of some of the program changes and observed radiation safety during maintenance performance. No deficiencies were identified.
On September 14, the inspector observed radiation safety personnel perform a survey of Unit 1 shutdown cooling piping. Radiation safety personnel performed periodic surveys of the shutdown cooling piping to monitor for changing radiation dose rates when shutdown cooling was placed in service during the Unit 1 planned reactor coolant pump seal outage. During the survey, the radiation safety technicians identified increasing dose rates in piping located approximately seven feet above the 5 foot elevation of the Unit 1 auxiliary building. The technicians toak prompt action to maintain visual surveillance of the area until temporary high radiation boundaries could be established. Subsequently, the area was fenced to establish positive high radiation area access controla. BGE radiological controls activities when placing Unit 1 on shutdown cooling were appropriate,
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F2 Status of Fire Protection Facilities and Equipment F2.1 Emeraenev Liahtina Followuo (92904)
a.
,1soection Scoce The inspectors reviewed BGE corrective actions to previously identified emergency lighting deficiencies and the reliability of emergency lighting during the time between surveillance tests, b.
Observations and Findinos As part of the implementation of 10 CFR 50, Appendix R, BGE initiated blackout testing of emergency lighting in all plant areas required for safe shutdown. The inspectors observed the performance of blackout testing of the emergency lighting capabilities in two plant areas: (1) 2A emergency diesel generator room; and (2)
Unit 2 service water room. These were the final areas in the plant tested. This testing was done with operations personnel to verify the 1C CFR 50 Appendix R
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design basis. The inspector found that the emergency lighting was acceptable in both rooms although the lighting at the south end of the lower level of Unit 2 service water room was marginal. BGE planned to modify and retest the emergency lighting in this room as part of the service water heat exchanger replacement activity currently scheduled for the 1998 refueling outage. The inspector noted, that for the remaining areas observed, the emergency lighting design in the rooms was robust enough to compensate for minor lighting misalignments and in some cases the loss of a single light head. However, the inspector concluded that the loss of an emergency lighting unit with several heads may result in inadequate lighting being provided to the area intended to be covered. BGE personnel
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acknowledged the inspectors conclusion, in addition to blackout testing, BGE used preventive maintenance work orders (PMs)
to periodically assess the functionality of emergency lighting fixtures. BGE used these PMs to ensure that the lights will provide eight hours of adequate lighting to support operators in abnormal or emergency operating procedures during accidents or transients. The PMs included both an operational and aiming check, and an eight hour discharge test. Quarterly, the emergency lighting units were verified to operate without dimming for a three to five minute period. The inspectors reviewed a sample of seven of these quarterly PMs completed during the second and third quarters of 1997 and found that the failure rate of the lighting fixtures was four to eight percent. No tests were completed without emergency lighting failures.
To verify the that the emergency lighting units were maintaining their 8-hour capability, BGE began to perform 8-hour discharge tests on all the installed emergency lighting units. Approximately twenty l' anting units spread throughout the plant were selected for a deep discharge test wch quarter. BGE expected that it would take 5 years to test all of the approximately 400 emergency lighting fixtures. At the time of the inspection, five of these tests were completed with U
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failure rates of 12 to 24 percent. No tests were completed without emergency lighting failures.
Discussions with BGE personnel indicated that the service life was not known for
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some of the batteries in the installed lighting fixtures. The inspector noted that
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the 15 year service life specified for the batteries by the vendor was affected by
changes in ambient temperature. The inspectors noted that according to the vendor and information provided by the Electric Power Research Institute (EPRI) a 15 degree Fahrenheit ('F) increase in average ambient temperature reduced the battery service life to seven and one half years. The inspectors also noted that the amblent temperature of some of emergency battery lighting units can be 120*F or greater, while the design temperature was near 77 F. BGE had not ovaluated service life for the high temperature environments and did not track service life for many of the existing lighting units,
i Through < iscussioris with BGE personnel, the inspectors determined that BGE did not have vendor supplied maintenance and testing information for the installed
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emergency lighting units. However, BGE die have EPRI guidance for the testing and maintenance of the lights.' The inspectors found that BGE did not complete the testing recommended by EPRI for the lighting units, including: (1) semi annual float voltage checks; (2) BGE performed functional testing quarterly vice the monthly
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testing recommended by EPRl: and, (3) BGE had begun battery discharge (8-hour)
performance testing but has not performed this testing annually on all units as
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recommended by EPRI.
The system engineer trended the performance of the emergency lights. The trending was based on information provided to the system engineer by electrical maintenance personnel during the testing. The inspector compared this trending database to the emergency light failures identified by the problem reporting system
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and found that some problem reports were not in the engineer's data base. BGE
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these types of failures. However, the inspector noted that several lightirig fixtures
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have had repeated failures in a one year period. The inspector also noted that as of the end of this inspection period, BGE had not identified corrective actions to address these repeated failures. BGE personnel indicated that the significance of failed lighting units was recognized and a policy had been established to correct failed lights as priority maintenance items. However, BGE had not completed an operability evaluation for operation with the observed emergency lighting unit failure rate of 24 percent.
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Conclusions The inspectors concluded that BGE has adopted a testing and maintenance process for emergency lighting units that allowed the units to remain in operation until they failed. The inspectors noted that a verification of emergency lighting capability and function was not performed when lighting units were determined to be inoperable.
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BGE had generic problems with emergency lighting units at Calvert Cliffs; however, insufficient corrective actions has led to continuing failures of the tested emergency lighting fixtures. Failure to adequately review test results and take corrective.
actions to prevent repetition was considered a violation (VIO 317 & 318/97 05 04).
F8 Miscellaneous Fire Protection issues F8.1 Main Control Room Fire Sucoression Review a.
insoection Scope (71750)
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Recently, another licensee experienced the inadvertent discharge of their main control room halon system when a flash camera picture of the open halon control panel was taken. The licensee evacuated the control room as a precaution. The inspectors reviewed the Calvert Cliffs control room fire protection design and procedures for susceptibility to a similar event.
b.
Findinas and Observations h.3 inspectors found that Calvert Cliffs does not have fixed / automatic fire suppression in the control room. BGE requested relief from the fire suppression requirements of section Ill G.2 of Appendix R to 10 CFR Part 50 for the control room at Calvert Cliffs Units 1 and 2. Since alternate safe shutdown means were provided for the control room, relief from the fixed fire suppression system requirements of Subsection Ill.G 3 were granted in an NRC exemption and letter dated April 21,1983.
BGE maintained 23 self-contained breathing apparatus (SCBA) for use by control room and technical support center (TSC) personnel, in a July 27,1982, letter responding to the control room habitability guidance in NUREG-0737, BGE committed to 15 SCBA for control room reserves based on a WASH 1400 class 9 accident. This supply was to last 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. The inspectors verified that there are 15 SCBA in the control room with 8 and 7 in the Unit 1 and Unit 2 computer rooms, respectively. The inspectors determined that there were 8 additional SCBA in the hallway outside the Technical Support Center. The inspectors noted that these SCBA were stored outside the control room ventilation and habitability envelope.
The emergency planning unit periodically inventoried these SCBA to verify proper quantity and location of emergency equipment. The inspectors confirmed that radiation safety personnel inspected these SCBA to ensure that they appeared in good working order and that the air bottles had been hydrostatically tested within the last three years. The inspectors also verified that fire and safety personnel tested the SCBA regulators semi annually. The inspectors verified the completion of these tests and inspections through a sample of 1997 records of tasks completed for the control room SCBAs.
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c.
.Qonclusions The inspectors found that there was no fixed or automatic fire suppression system in the control room and this configuration was supported by an exemption from Appendix R to 10 CFR Part 50. Therefore, Calvert Cliffs was not susceptible to an inadvertent control room fire suppression system actuation.
V. Manaaement Meetinos X1 Exit Meeting Summary During this inspection, periodic meetings were held with station management to discuss inspection observations and findings. On October 1,1997, an exit meeting was held to summarize the conclusions of the inspection. BGE management in attendance acknowledged the findings presented.
On September 10 and 11,1997, Mr. W. Axelson, Deputy Regional Administrator, Region I and other NRC managers listed in Attachroent 1 visited Calvert Cliffs Nuclear Power Plant. The visit included a site tour and discussions with various site individuals in operations, maintenance, radiation controls, engineering, and quality assurance. Discussions were also held with members of BGE management.
X2 Review of UFSAR Commitments A recent discovery of a licensee operating its facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR description. While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected to verify that the UFSAR wording was consistent with the observed plant practices, procedures and/or parameters.
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O ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED EGE P. Katz, Plant, Plant General Manager K. Cellers, Superintendent, Nuclear Maintenance K. Neitmann, Superintendent, Nuclear Operations
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P. Chabot, Manager, Nuclear Engineering T. Pritchett, Director, Nuclear Regulatory Matters B. Watson, General Supervisor, Radiation Safety C. Earls, General Supervisor, Chemistry L. Gibbs, Director, Nuclear Security-T. Sydnor, General Supervisor, Plant Engineering.
T. Forgette, Director - Emergency Preparedness C. Cruse, Vice President NBC W. Axelson, Deputy Regional Administrator, Region I W. - Hehl, Director, Division of Reactor Projects, Region i J. Wiggins, Director, Division of Reactor Safety, Region i L. Doerflein, Chief, Reactor Projects Branch 1, DRP, Region i A. Dromerick, Acting Director, Project Directorate 11, Office of Nuclear Reactor Regulation INSPECTION PROCEDURES USED l
IP 62703: Maintenance Observation IP 71707: Plant Operations IP 93702: Prompt Onsite Response to Events at Operating Power Reactors IP 61726: Surveillance Observations IP 37550: Engineering IP 37551: Onsite Engineering IP 71750: Plant Support Activities IP 83750: Occupational Exposure IP 92700: Onsite Followup of Written Reports of Events at Power Reactor Facilities IP 92902: Followup - Engineering IP 82701: Operational Status of the Emergency Preparedness Program
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Attachment 1
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ITEMS OPENED, CLOSED, AND DISCUSSED
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Opened 50-317&318/97 05 01 URI Appendix R lights are not in BGE maintenance rule
50 317&318/97-05-02-VIO Inadequate corrective actions for compression fitting problems 50-317&318/97 05-03 IFl Evaluation of containment tendon surveillance test 50-317&318/97-05 04 VIO Failure to implement corrective actions for failed
emergency lights Closed 50-317/97 005 LER Reantor Coolant System Leak Due to i.ined Fitting i-
LIST OF ACRONYMS USED
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- Diesel Generator i
Fxy Total Planar Radial Peaking Factor LCO Technical Specificat;on Limiting Condition for Operation
NFM Nuclear Fuels Management RCA Root Cause Analysis
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SWP Special Work Permit
UFSAR Updated Safety Analysis Report MO ~
Maintenance Order i
- LER Licensee Event Report RCS Reactor Coolant System
LPSI Low Pressure Safety injection EDG Emergency Diesel Generator -
IR issue Report QA Quality Assurance SCBA Self Contained Breathing Apparatus
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LOCA Loss of Coolant Accident EPRI Electric Power Research Institute o
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