ML20052B409
| ML20052B409 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/13/1982 |
| From: | Architzel R, Mccabe E, Mccabe S, Trimble D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20052B378 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.1, TASK-2.B.2, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-317-82-05, 50-317-82-5, 50-318-81-5, 50-318-82-05, 50-318-82-5, IEB-80-06, IEB-80-6, NUDOCS 8204300385 | |
| Download: ML20052B409 (20) | |
See also: IR 05000317/1982005
Text
DCS Noo 317820314
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U. S. NUCLEAR RE6ULATORY COMMISSION
Region I
50-317/82-05
Report Nos.
50-318/82-05
50-317
Docket Nos.
50-318
C
License Nos. DPR-69
Priority
Category
C
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Licensee:
Baltimore Gas and Electric Company
P. O. Box 1475
Baltimore, Maryland 21203
Facility Name: Calvert Cliffs Nuclear Power Plant, Units 1 and 2
Inspection At: Lusby, Maryland
Inspection Conducted: March 2 - April 13,1982
Inspectors:
g .,
R. E.' Architzel, Senior' Resident Reactor Inspector
date signed
A e. O Gf
4 /n la
D. C. Trimble, Resident Reactor Inspector
date signed
Approved by:
6Px kO*M
4 IISIE7.
E. C. McCabe, Jr., Chief, Reactor Projects Section 2B
date signed
Inspection Summary:
Inspection on 03/02-04/13/1982 (Combined Report Nos. 50-317/82-05 and 50-318/82-05)
Areas Inspected: Routine, onsite regular and backshift inspection by the resident
inspector (196 hours0.00227 days <br />0.0544 hours <br />3.240741e-4 weeks <br />7.4578e-5 months <br />). Areas inspected included the control room and the accessible
portions of the auxiliary, turbine, service, and intake buildings; radiation protection;
physical security; fire protection; plant operations; plant cperating records; mainten-
ance; surveillance; radioactive waste releases; open items; IE bulletins; THI Action
Plan Items; and reports to the NRC.
Violations: Three: Failure to post a radiation area as required (detail 4.b),
failure to control drawing changes (detail 8), and failure to conduct required
safety reviews for facility changes (detail 8).
8204 3 0 0 3 8 tf
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1.
Persons Contacted
The following technical and supervisory level personnel were contacted:
J. Alvey, Security, Shift Supervisor
G. E. Brebst, General Supervisor, Chemistry
D. E. Buffington, Fire Protection Inspector
D. P. Butler, Principal Control Technician
E. L. Campo, Supervisor, Surveillance and Receipt Inspection
J. T. Carlson, Supervisor, Radiation Safety
J. T. Carroll, General Supervisor, Operations
S. E. Cherry, Principal Chemistry Technician
P. T. Crinigan, Senior Engineer, Chemistry
F. S. Deller, Control Technician
R. E. Denton, General Supervisor, Training / Technical Services
C. L. Dunkerly, Shift Supervisor
H. A. Eggleston, Supervisor, Administrative Services
T. N. Gibson, Control Electrician
W. S. Gibson, General Supervisor, Electrical & Controls
J. E. Gilbert, Shift Supervisor
K. M. Higgins, Control Technician
5. G. Hutsen, Principal Radiation-Chemistry Technician
S. E. Jones, Supervisor, Training
D. W. Latham, Principal Engineer, Operational, Licensing & Safety Unit
R. O. Mathews, Assistant General Supervisor, Nuclear Security
B. Moffit, Senior Nuclear Security Officer
G. S. Pavis, Engineer, Operations
J. E. Rivera, Shift Supervisor
L. B. Russell, Plant Superintendent
J. A. Snyder, Supervisor, Instrument Maintenance Unit 2
T. L. Sydnor, General Supervisor, Operations QA
J. A. Tiernan, Manager, Nuclear Power Department
R. L. Wenderlich, Engineer, Operations
R. V. Wyvill, Radiation-Chemistry Technician
D. E. Yates, Senior Electrician
D. Zyriek, Shift Supervisor
Other licensee employees were also contacted.
2.
Licensee Action on Previous Inspection Findings
(Closed) Violation (317/79-23-02) Failure to Correct a Grounded Condition on the
21 DC Battery Bus. The licensee's corrective actions for this item had previously
been inspected (Report 317/81-27) and left open pending NRC review of an approved
Battery Ground Isolation Procedure. The inspector reviewed maintenance proce-
dures BAT-7 and BAT-8, Battery Ground Temporary Isolation, approved January 13,
1982. These procedures address the temporary nature of procedure use (conduct
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requires constant observation) and appropriate precautions, including checks
for proper polarity and equalization of voltages to avoid current shifts. The
inspector also observed implementation of the procedure on March 11, 1982
during the isolation of a ground on DC Bus 11.
(Closed) Unresolved Item (317/81-07-03; 318/81-07-01) Status of Cable Spreading
Room Halon Systems. The licensee has completed operational testing of Halon
Fire Suppression Systems in the Cable Spreading and Switchgear Rooms.
Portions
of this testing were observed by the inspector. An evaluation of the installed
systems capabilities was reviewed by the inspector (Report 317/81-18; 318/81-17)
and forwarded to NRR for additional review. The licensee sent a letter dated
February 24, 1982 confirming telephone conversations with NRR regarding the
ability of the system to reach design concentrations (greater than 7%,1 css
than 10%) and to maintain at least extinguishing concentrations for 10 minutes.
A Safety Evaluation Report issued March 18, 1982 documented the NRC's conclusion
that the fire and smoke detection and suppression systems in the Cable Spread-
ing Room and associated cable chases met the requirements of Section III.G of
Appendix R to 10CFR50 and are acceptable.
(Closed) Violation (317/81-18-05; 318/81-17-06) Failure to follow Radiation-
Chemistry Procedure (RCP) 1-601. The licensee responded to this item in a
letter dated December 1, 1981. The inspector verified the corrective action
taken, including revision of RCP l-601 (Revision 2 dated 11/25/81 reviewed)
to require hand calculation of response factors and a modification to the
Operations Notes Section to document plant computer setpoint changes for the
Liquid Waste Monitor Alarm prior to discharging liquid waste.
Inspector
observation of calculations by chemistry technicians confirmed they were
following the revised procedure. A copy of the licensee's response was also
circulated to chemistry technicians as an additional reminder for the hand
calculation.
(Closed) Unresolved Item (318/81-20-01) Flow Verification for Penetration Room
Exhaust Ventilation System. The inspector reviewed Surveillance Test Proce-
dure STP-M544, Penetration Room Exhaust Filter Test (HEPA) and verified that
a flow verification is required. This test is required every 18 months or 720
hours of filter operation, whichever is sooner.
3.
Review of Events Requiring One Hour Notification to the NRC
About 4:30 p.m. on March 14, 1982 the pilot of a light aircraft made an
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emergency landing on Baltimore Gas and Electric Company property west
of the plant site and outside the security boundry. There were no serious
injuries, and the pilot was alone in the plane. Plant security personnel
found the aircraft unattended about 6:30 p.m.
An Unusual Event was de-
clared at 6:40 p.m. and terminated at 7:30 p.m.
The inspector visited
the landing area and discussed the incident with the Shift Supervisor and
security personnel. The landing area is not visible from within the plant
security boundry. That caused the two hour delay in learninf of the event.
Also, the pilot did not report the event to security personnel..
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A Radiological Event was declared about 10:40 a.m. on March 15, 1982.
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(A one hour report was not required ormade.) An increase was noted
in Main Vent Particulate Monitor reading
Samples in the Auxiliary
Building showed low level particulate (Rb-88, 3.7 E-8 uC/cc). The
particulate contribution to the site release rate was negligible (about
1% of Technical Specification limit due to noble gases). Unit 1
Auxiliary Building ventilation had been secured for maintenance prior
to the event and was restarted. The inspectors observed the licensee's
response to this event from both the Control Room and Health Physics
Office / Chemistry Laboratory. The actions were according to the
Emergency Response Plan Implementing Procedures. Because of the low
ievels, reporting to the NRC was not required. Particulate activity in
the Main Vent was noted at a maximum of 2.58 E-10 uC/cc (Rb-88). No
gaseous activity was detected.
(The Minimum Detectable Activity
(MDA) for Kr-88, the parent of Rb-88, was 1.35 E-7 uC/cc.) The licensee
determined the probable cause of the increase to be slight gas leakage
which occurred in the 27' West Penetration Room during the venting of
the Reactor Coolant Drain Tank about 10:00 a.m.
With the Auxiliary
Building Ventilation secured, the radiogas daughters were allowed to
build up to detectable levels. Auxiliary Building air samples taken
during this event showed a maximum MPC of 0.288 due to particulate
activity (6.43 E-8 uC/cc) at 10:45 a.m. in the 27' Unit 1 West Penetration
Room. The licensee directed personnel in the building to leave and
required the use of respirators and full anti-contamination clothing
in the building during the event. The Radiological Event was declared
ended at lill p.m. following return to normal airborne levels.
At 2:12 p.m. on April 7,1982 the Unit 1 pressurizer was inoperable due
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to a greater than -5% deviation from its programmed value. The cause
was a pressure variation in the reference leg for pressurizer level
transmitter 110Y.
I&C technicians in the containment were restoring
Pressurizer Pressure Channel C to service following corrective maintenance
(MR 0-82-1452). The pressure transmitter senses off the 110Y level
transmitter's reference leg, thus a step change in level was sensed
(216 to 195 inches) when the pressure channel was restored. All three
charging pumps started and letdown was isolated. The operator switched
to the other Control Channel, 110X, which had increased to 230 inches
due to the charging pumps and letdown isolation. Pressurizer levels
were back to normal program by 2:35 p.m.
Measures to prevent recurrence
will be subsequently inspected (317/82-05-04).
4.
Review of Plant Operations
A.
Daily Inspection
The inspector toured the facility to verify proper manning and access
control, and observed adherence to approved procedures and LCOs.
Instrumentation and recorder traces were observed. Status of control
room annunciators was reviewed. Nuclear instrument panels and other
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reactor protective systems were examined.
Control rod insertion limits
were verified. Containment temperature and pressure indications were
checked against Technical Specifications. Stack monitor recorder
traces were reviewed for indications of releases.
Panel indications
for onsite/offsite emergency power sources were examined for automatic
operability. Control room, shift supervisor, and tagout log books, and
operating orders were reviewed for operating trends and activities.
During egress from the protected area, the inspector verified operability
of radiological monitoring equipment and that radioactivity monitoring
was done before release of equipment and materials to unrestricted use.
These checks were performed on the following dates: March 3, 4, 5, 8,
9, 11, 15, 16, 18, 19, 23, 24, 25, 30, April 1, 2, 5, 6, and 7, 1982.
-- On March 3,1982 the inspector noted that Loose Parts Monitor
Channel 27 (for the number 22 Steam Generator) was in alarm.
Operations personnel onshift believed that the channel was not
operating properly but a Maintenance Request (MR) had not been
initiated. The inspector pointed this out to the Shift Supervisor,
and the appropriate MR was initiated.
On March 5,1982 the inspector noted the following problems:
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- Loose Parts Monitor Channel 23 (for the Unit 2 Reactor Vessel
top) was in alarm;
- A Unit 1 Radiation Monitor Recorder was not functioning properly;
- The 200-foot high Wind Direction Recorder was not functioning
properly.
A MR was initiated on March 6 for Loose Parts Monitor Channel 23.
The Radiation Monitor and Wind Direction Recorders were expeditiously
repaired.
On March 16 the inspector noted that the M-2 indicator light on the
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Unit 2 Reactor Trip Status Panel was not functioning properly. The
inspector pointed this out to the Senior Control Room Operator,
and the light was immediately repaired.
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-- On March 9 the inspector observed that the Salt Water Control Valves
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for both Unit 1 Component Cooling Water (CCW) heat exchangers were
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closed.
CCW temperatures were within nomal limits.
Discussions
with Control Room personnel revealed that the butterfly-type control
valves were apparently passing sufficient leakage water when closed
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to allow adequate cooling. The inspector noted that no maintenance
action had been initiated to repair the leaking valves, which receive
a signal to close on a Safety Injection and open on Recirculation
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Actuation. The licensee initiated MR-0-82-1109 to repair the leaking
valves,
The timeliness of initiation of repair of safety-significant components will
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be subsequently inspected (317/82-05-05, 318/82-05-06).
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B.
Weekly System Alignment Inspection
Operating confirmation was made of selected piping system trains.
Accessible valve positions in the flow path were verified correct.
Proper power supply and breaker alignment was verified. Visual
inspections of major components were performed. Operability of
instruments essential to system performance was verified. The
following systems were checked:
-- High Pressure Safety Injection trains 13 and 23 on Unit 2
Service Water System in the Service Water Pump Room, and pip-
ing for the Containment Coolers and Diesel Generators in the
Auxiliary Building on March 10.
-- Containment Spray train 21 on March 11.
Diesel Generator Starting Air System on March 26.
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Lineup of suction piping to the Refueling Water Tank for both
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trains of High Pressure Safety Injection, Low Pressure Safety
Injection, and Containment Spray for Units 1 and 2 on March 25.
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Containment Spray train 11 on April 7.
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On March 25 the inspector noted that the Unit 2 Refueling Water Tank
Room was not posted as a radiation area when his survey of the room
measured general area radiation levels of up to 4 millirem per hour,
representing about 160 millirem in a normal 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, 5 day week.
10CFR20.203(b) requires conspicuous posting of each radiation area
with a sign or signs bearing the radiation caution symbol and the words
" Caution" and " Radiation Area".
10CFR20.202(b)(2) defines a radiation
area as an accessible area where a major portion of the body could
receive more than 5 millirem in any one hour or more than 100 millirem
in any 5 consecutive days. The inspector pointed this out to Radiation
Chemistry personnel who stated that the room had previously been posted
but that the sign was orobably removed inadvertently during a recent
maintenance activity in the area. The licensee's last survey of the
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area, conducted on March 11, 1982, had indicated general area readings
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of up to 3 millirem per hour representing about 120 millirem in a normal
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40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, 5 day week. A licensee Radiation-Chemistry Technician accompanied
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the inspector on a followup survey which also indicated general area
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readings of up to 4 millirem / hour.
Failure to comply with requirements
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of 10CFR20,203(b) is a violation (318/82-05-01). The room was, however,
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locked when not in use and controlled as a contaminated area.
On April 7, Containment Spray Pump 11 was tagged off and the normally
open manual valve 1-SI-319 was tagged shut for maintenance on relief
valve 431. The licensee was in the action statement for Technical
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Specification 3.6.2.1.
Containment Spray train 12 was operable. No
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unacceptable conditions were identified.
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C.
Biweekly Inspection
Verification of the following tagouts indicated the action was properly
conducted.
-- Tagout 2208, Unit 2 Safety Injection Tank outlet valve breakers,
verified on 3/5/82.
Tagout 2318, MSIV 11 Accumulator 7 repair, verified on 3/16/82.
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Lifted Leads 1-80-59 (5 leads)and 2-81-45(10 leads), Units 1
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and 2 Reactor Coolant Vent System disabled, on 3/24/82.
Tagout 2194, Unit 2 Containment Purge Isolation Valves, verified
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on 4/7/82.
Boric acid tank samples were compared to the. Technical Specifications.
Tank levels were also confirmed. No unacceptable conditions were identified.
D.
Other Checks
During plant tours, the inspector observed shift turnovers, security
practices at vital area barriers, completion and use of radiation work
permits, protective clothing and respirators. The use and operational
status of personnel monitoring practices, and area radiation and air
monitors were reviewed.
Equipment tagouts were sampled for conformance
with TS LCOs.
Plant housekeeping and cleanliness were evaluated including
checks for ignition sources and flamable materials. Other TS LCOs,
including RCS Chemistry and Activity, Secondary Chemistry and Activity,
watertight doors, and remote instrumentation were checked.
On March 16, the inspector observed the conduct of a radiation survey
in the vicinity of an alarming Unit 1 Blowdown Monitor. The radiation-
levels were normal in the vicinity of the monitor. Subsequent checks
showed that the installed instrument was grounded and action was initiated
to repair the monitor.
On March 15, sparks from a welding operation caused a small fire in
combustible trash material beneath a grating in the Unit 2 steam line
Penetration Room. The individual acting as firewatch imediately extin-
guished the fire. On March 16, the inspector visited the scene of the
fire and discussed the event with the firewatch who had extinguished
the fire. The inspector discovered that an earlier report.on the fire,
which had been provided to the licensee's organization by a subcontractor
in charge of the welding activity, incorrectly attributed the cause of
the fire to weld slag smouldering in folds in the fire blanket.
The
inspector pointed out this discrepancy to licensee personnel'.
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During a routine inspection on March 30, the inspector noted that the
Unit 2 Chemical and Volume Control System process radiation monitor has
been tagged out-of-service since October 26, 1978 and the boronometer
since November 11, 1981. Both instruments are described in the Units 1
and 2 Final Safety Analysis Report and, therefore, are part of the facility
design basis upon which the plant was originally licensed. The NRR
Project Manager for Calvert Cliffs discussed the lengthy out-of-service
time for these monitors with the Plant Superintendent to better understand
the licensee's intention regarding repair efforts. The Plant Superintendent
indicated that the boronometer is expected to be repaired in about a week.
He indicated that repair efforts are continuing on the radiation monitor
and that problems have been encountered in obtaining a particular printed
circuit board. This item is unresolved, pending licensee action and
subsequent NRC:RI review (317/82-05-01 and 318/82-05-02).
5.
Plant Maintenance
The inspector observed and reviewed maintenance and problem investigation
activities to verify compliance with regulations, administrative and
maintenance procedores, and codes and standards, proper QA/QC involvement,
safety tags use, equipment alignment, jumper use, personnel qualifications,
radiological controls for worker protection, fire protection, retest require-
ments, and reportability per Technical Specifications. The following
activities were included.
MR-0-82-1052, observed a ground isolation procedure on the 125 Vdc
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bus 11 on 3/11/82.
MR-M-82-2259, observed filter replacement to correct a low suction
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pressure on MSIV 22 hydraulic package on 3/16/82.
M-82-6030 (FCR 79-1062) install raceways for modifications to Auxiliary
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Feedwater System, observed core boring in the Unit 1 Cable Spreading
Room west wall for conduit ZA 144254 on 4/5/82.
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MR-0-80 -1496, observed the troubleshooting of failed Reactor Coolant
System hot and cold leg temperature elements TE 125 and 121Y on 4/8/82.
No unacceptable conditions were identified.
6.
Surveillance Testing
The inspector observed parts of tests to verify performance in accordance with
approved procedures, LCOs were satisfied, test results (if completed) were
satisfactory, removal and restoration of equipment were properly accomplished,
and that deficiencies were properly reviewed and resolved. The following tests
were reviewed.
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STP L-171-1, Unit 1 Personnel Air Lock seal test, observed on 3/13/82.
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STP M-544-1, Unit 1 Penetration Room Exhaust filter test (HEPA), observed
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on 3/31/82.
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STP M-210B-2, Unit 2 Reactor Protective System functional test on 4/8/82
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No unacceptable conditions were identified.
7.
Observation of Physical Security
The resident inspector checked, during regular and offshift hours, on whether
selected aspects of security met regulatory requirements, ohysical security
plans, and approved procedures. The following were found acceptable.
A.
Security Staffing
Observations and personnel interviews indicated that a full time
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member of the security organization with authority to direct
physical security actions was present, as required.
Manning of all three shifts on various days was observed to be
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as required.
B.
Physical Barriers
Selected barriers in the protected area (PA) and the vital areas (VA)
were observed. Random monitoring of isolation zones was performed.
Observations of truck and car searches were made.
C.
Access Control
Observations of the following were made:
Identification, authorization, and badging;
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-- Access control searches;
Escorting;
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-- Communications; and
Compensatory measures when required.
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8.
Licensee Action on NUREG 0660, NRC Action Plan Developed ~as ~a' Result of'the
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TMI-2 Accident
The NRC's Region I Office has inspection responsiblity for selected action plan
items. These items have been braken down into numbered descriptions (Enclosure
1 to NUREG 0737, Clarification of TMI Action Plan Items). Licensee letters
containing commitments to the NRC were used as the basis for acceptability,
along with NRC clarification letters and inspector judgment. The following
items were reviewed.
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II.B.1(3) Reactor Coolant Vent System Procedure. The licensee forwarded
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guidelines to be used in the development of the Reactor Coolant System
Gas Vent System (RCSVS) in a letter dated August 11,1981. The letter
stated that the RCSVS would be operational by January 1,1982 and that
formal training and operating instructions would be issued by that time.
The installation and associated procedures for II.B.1 require preimplementa-
tion approval (NUREG 0737) so the licensee was not able to implement on
the comitted date.
(NRC has not completed its review.) The inspector
reviewed procedure 0I-16, Reactor Coolant Vent System, Revision 0, approved
December 30, 1981. The procedure contained the major guideline points in
a condensed, more useable fashion. One note in the procedure stated that
a sign of non-condensible gases in the RCS was that pressurizer level could
not be raised when pressure increases during charging. The inspector
stated that this note seemed in error in that pressurizer level increases
would result in pressure changes with non-condensibles present, although
the response would be different than if the vapor space only contained
water vapor (inconsistent response). The licensee stated that this
aspect would be reevaluated prior to implementing the RCSVS. Training
for the RCSVS procedure has been scheduled during the Licensed Ooerator
Requalification Training Program for 1982. The licensee stated that this
training would be completed by November,1982. The NRC sent a letter to
the licensee (dated March 9,1982) with additional questions on the RCSVS
and on the procedure guidelines. Discussions with licensee personcel
revealed that the reviewer also had requested and received the licensee's
procedure. TAP Item II.B.l(3) will remain open pending NRC approval of
the guidelines, review of the revised procedure (if necessary), and
completion of training.
II.B.l(2) Reactor Coolant Vent System. The licensee has installed a
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Reactor Coolant System Vent System (RCSVS). The system was installed
by Facility Change Request 79-1054, portions of which were reviewed by
the inspector. The system is required to be implemented by July 1,1982,
however, a preimplementation review by the NRC is required. The NRC is
reviewing the licensee's installation; a letter requesting additional
information was sent to the licensee on March 9,1982.
In the interim,
the licensee comitted to disable the installed system pending NRC review
and approval (BG&E letter dated December 18, 1980).
The inspector examined Lifted Lead serial sheets 1-80-59 (Unit 1, approved
December 16,1980) and 2-81-45 (Unit 2 approved March 7,1981). These
lifted leads disabled the five solenoid valves for each unit's RCSVS by
opening power to the solenoids. Valve position indication circuits were
left intact. The inspector noted that Unit 1 and 2 lifted leads were not
the same. On Unit 1 the slide links had been opened for power both to
and from the solenoids (black and white leads); for Unit 2, four supply
leads (black) had been lifted at the slide links and one set of slide
links opened. The inspector further noted that one of the leads had
been lifted at a terminal point labeled H-59, when the sheet called for
point H-58
Investigation showed that the lead was properly lifted and
that the terminal was incorrectly pencil marked. The licensee removed the
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improper marking.
Inspector investigation of the schematics associated
with these lifted leads revealed a problem with the licensee's controlled
drawings, however, the solenoids were determined to be adequately disabled
per the Lifted Lead Index Sheets.
Licensee personnel informed the inspector that the only drawings showing
the interconnections inside the control room panels (the leads were lifted
at Panel 2006, the Reactor Control System Control Board) were vendor
drawings (Reliance Inc.) which were maintained in the Instrument and
Controls Shop. The applicable drawing (BG&E Drawing Number 87-306-E,
Sheet 14, Revision 0 updated in 1981; previously Bechtel Drawing Number
6750-M-346-11-5, Sheet 14) did not show the internal panel wiring at the
terminals. The print was marked as controlled by the BG8E Print Room,
however, no Prawing Change Notices (DCNs) were listed in the applicable
box. The inspector reviewed the BG&E Drawing 63-101-E SH 6A, Revision 6,
Connection Diagram Reactor Coolant Control Board 2006, Electric Shop
controlled copy and noted that DCNs were listed; one of these 63-10lSH6A-2
issued August 1,1980 showed one side of the connections in question,
however, only field wiring was shown, not internal wiring which is shown
o'1 the vendor prints.
The inspector questioned the technicians concerning how they had known
which leads to lift. They stated that drawings had been provided with
FCR 79-1054. The inspector reviewed the FCR package and found a vendor
DCN, VDCN 13374A15SH15-1 which described the wiring changes. The Unit 2
I&C Supervisor was unfamiliar with this numbering system and was unable
to recover the VDCN from the I&C Shop DCN catalogs. The inspector went
to the BG&E print room, which controls issuance of drawings at the site
to attempt to recover the VDCN. The print room sepia for Drawing 87-306-E,
Sheet 14 was not listed as controlled and did not list DCNs. A search
of the DCN books by both Bechtel DCN Number (M-346-116) and BG&E folder
number (13374A15) revealed the following DCNs applicable to Sheet 14
of the drawing:
DCN
Date Received
Description
M-346-116-2018
11/?l/77
FCR 76-1054, Power Operating Relief
Valve Dual Setpoint Capability
M-346-116-2026
05/06/80
FCR 79-1043, New Terminal Strips
and Wiring for Subcooled Margin
Monitor
M-346-116-2032
12/16/80
FCR 80-1015, Annunicator Relocation
13374A15SH14-1
08/06/80
FCR 79-1054, Reactor Coolant System
Vent System
13374A15SH14-3
01/07/81
FCR 79-1045, Installation - Technical
Support Center
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DCN
Date Received
Description
13374A15SH14-4
01/16/81
FCR 79-1054, Reactor Coolant System
Vent System
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13374A15SH14-5
01/23/81
FCR 79-1045, Installation - Technical
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Support Center
Print room personnel indicated that the problem may have been their reliance
on recent drawing changes (1981) which were making Bechtel Drawings into
BG&E drawings.
(The drawings received listed some, but not all outstand-
ingDCNs.)
In addition, the use of BG&E folder numbers had been confusing
i
and tnese had not been transferred onto the vendor prints. Failure to
control drawing changes as required by the Operations Quality Assurance
Program is a violation (318/82-05-03). TAP Item II.B.1(2) remains open
pending completion of NRC preimplementation review, additional changes if
necessary and reinspection.
II.F.1 Attachment 1, Noble Gas Effluent Monitor and Attachment 2, Sampling
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and Analysis of Plant Effluents. The licensee has installed a Noble Gas
Effluent Monitoring System to implement TAP Item II.F.1. FCR 79-1058,
Noble Gas Effluent Monitor, and Supplements 1-9 (Unit 1) and 1-8 (Unit 2)
implemented the change.
In addition to the Facility Changes and
supplements, the following documents were reviewed by the inspector:
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Information Statement for Wide Range Effluent Gas Monitor (WRGM)
dated 8/19/81.
Safety Analysis for FCR 79-1058 dated 12/23/80 (OSSRC approved in
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meeting 81-4).
CC Training Memorandum 82-TS-3, General Overview of WRGM, conducted
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by Vendor Technical Representative on 1/21/82.
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Preliminary System Description, Wide Range Effluent Gas Monitor
(WRGM) dated 12/16/81.
Facility Engineering Changes through No. 56 for FCR 79-1058.
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The licensee has encountered numerous equipment problems during system
debugging and preoperational testing. No unacceptable conditions have
been identified during the present inspection, however, additional items
remain to be inspected following licensee completion of installation and
testing. TAP Item II.F.1 remains open pending completion of installation
testing and NRC inspection.
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II.B.2 Plant Shielding. On 1/4/80 the licensee submitted the results
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of a study of post-accident dose rates in vital ereas which included
a list of modifications being considered to meet the reouirements of
NUREG 0578, item 2.1.6.b (Design Review of Plant Shielding of Spaces for
Post-AccidentOperations). A 4/7/80 NRC staff evaluation concluded that
the licensee had met the Category A (short term) requirements of item
2.1.6.b and stated that a detailed review of the (1/4/80) BG&E submittal
would be performed at a later date.
In a letter dated 12/15/80 the
licensee stated that no deviations to the NRC position on Design Review
of Plant Shielding (item II.B.2 of NUREG 0737, published 10/31/89)
were expected to be necessary.
Item II.B.2 of NUREG 0737 requires that
necessary plant modifications be completed by 1/1/82. The inspector review-
ed the modifications made by the licensee to meet item II.B.2 of NUREG 0737 requirements and noted the following:
The final list of " modifications completed" varied from the original
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list of " modifications being considered" as submitted in the licensee
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letter dated 1/4/80. Specifically, new shielding was not added in
the Radiation Exhaust Ventilation Equipment rooms, in the switch-
gear room 311, or near the containment airlock. An additional motor
operated valve was added in piping near SI-400 instead of installing
a motor operator to SI-400.. A new motor operated valve and
piping were added as e bypass path around CVC-269 instead of
installing a motor operator on CVC-269. Final shield wall locations
differ in some cases from those originally proposed. The inspector
did not review two modifications (Containment Air Sampling and Reactor
Coolant Liquid Sample) since they more directly respond to another
Action Plan Item, II.B.3.
Those modifications will be reviewed in
conjunction with the review of item II.B.3.
The modifications judged by the licensee to be necessary have been
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completed.
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As built drawings have been changed to reflect the modifications.
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Operator training on modifications has been scheduled for accomplish-
ment over the five-week period beginning April 5,1982.
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Operating Procedures have been changed to reflect new valve
installations.
The final list of modifications is:
Added core flush M0V's 1-SI-399, 2-SI-399,1-CVC-269, 2-CVC-269.
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New shielding in Emergency Core Cooling System (ECCS), decontamination,
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and component cooling rooms.
New shielding near the elevator on the five foot elevation of the
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Auxiliary Building.
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14
Shielding in the north-south hallway on the five foot elevation
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of the Auxiliary Building,
During his review of the engineering Facility Change package (FCR 80-
1009) on 3/26/82 the inspector could not locate a documented safety
evaluation addressing the addition of the below listed motor operated
valves and associated piping. The valves and piping had been added to
systems described in the Units 1 and 2 Final Safety Analysis Report
(FSAR).
flotor operated valves 1.SI-399 and 2-SI-399 added to existing
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Unit 1 and 2 cross-connection piping between the Low Pressure
Safety Injection and Shutdown Cooling Systems.
Motor operated valves 1-CVC-269 and 2-CVC-269 and associated
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piping providing a bypass path around existing manual valve
CVC-269 and check valve CVC-270 in the Units 1 and 2 Chemical
and Volume Control Systems.
This was pointed out to the responsible engineer who, after further
checking, was unable to find the subject safety evaluation. Additionally,
the problem was discussed with the General S,upervisor of Training and
Technical Services on 4/2/82 and with the Plant Superintendent on 4/5/82.
10CFR50.59(a)(1) permits a licensee to change a facility as described in
the FSAR without prior Conunission approval, only when a change in
Technical Specifications or an unreviewed safety question is not involved.
10CFR50.59(b) requires that records of such changes be maintained which
include written safety evaluations providing the bases for the determina-
tion that the changes do not involve an unreviewed safety questions.
Failure to comply with 10CFR50.59 is a violation (317/82-05-02 and 318/
82-05-04). TMI Action Plan Item II.B.2 will remain open pending NRC
review and approval of the licensee's shielding study and design, completion
of training, and equipment qualification.
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II.B.3 Post-Accident Sampling.
In a letter to the NRC dated 3/26/82.
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the licensee reported that final system testing / adjustment, and associated
shielding installation is not yet complete. A commitment was made to
'
provide an estimated completion date in a forthcoming letter. This item
will be addressed in a future inspection report.
9.
Review of Licensee' Event' Reports'(LERs)
LERs submitted to NRC:RI were reviewed to verify that the details were clearly
reported, including accuracy of the description of cause and adequacy of
corrective action. The inspector determined whether further information was
required from the licensee, whether generic implications were indicated, and
whether the event warranted onsite followup. The following LERs were reviewed.
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LER No.
Date of Event
Date of~ Report
Subject
Unit 1
82-02/3L
01/20/82
02/19/82
EXCESSIVE LEAK RATE PAST CONTAIN-
MENT EMERGENCY ESCAPE HATCH OUTER
D0OR.
82-03/3L
01/26/82
02/25/82
- 29 CELL OF 125 VDC BATTERY 12
WAS 0.04 V BELOW MINIMUM.
82-05/3L
01/29/82
02/26/82
- 12 CONTROL ROOM A/C UNIT TRIPPED
AND COULD NOT BE RESET.
82-06/3L
02/15/82
03/17/82
- 13 CONTAINMENT AIR COOLER FAN
82-07/3L
02/18/82
03/19/81
AUXILIARY FEEDWATER FLOW INDICA-
TION INOPERABLE.
82-08/3L *
03/03/82
03/22/82
- 11 COMP 0NENT COOLING HEAT EX-
CHANGER REMAINED ISOLATED FOR 13
HOURS AFTER MAINTENANCE.
Unit 2
82-02/3L
02/04/82
03/05/82
FEEDBREAKER 152-2101 TRIPPED OPEN
CAUSING LOSS OF POWER TO 21-4KV BUS.
82-03/3L
01/20/82
02/19/82
CTMT ATMOSPHERE GASEOUS RADIO-
ACTIVITY MONITOR INOPERABLE.
82-04/3L
02/11/82
03/12/82
- 22 STEAM GENERATOR PRESSURE
INDICATION ON REMOTE SHUTDOWN
MONITOR INSTRUMENT PANEL READING
HIGH BY 44 PSI.
82-05/3L
02/23/82
03/09/82
JET IMPINGEMENT BARRIER IN MAIN
STEAM PENETRATION ROOM NOT COMPLETELY
INSTALLED.
82-06/3L
02/19/82
03/19/82
LEAKAGE PAST CTMT PURGE SUPPLY AND
EXHAUST VALVES IN EXCESS OF TS.
82-07/3L
02/23/82
03/25/82
AUXILIARY FEEDRATER FLOW
INDICATION INOPERABLE.
82-08/3L
02/12/82
03/12/82
CONTAINMENT INNER DOOR INOPERABLE.
82-09/3L
02/06/82
03/08/82
PRESSURIZER LEVEL DEVIATED FROM
PROGRAM LEVEL BY MORE THAN 5%.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -
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Ln No.
Date of Event
Date'of Report
' Subject
Unit 2
82-10/3L
02/12/82
03/12/82
CEA-19 STUCK AT APPR0XIMATELY 8
INCHES WITHDRAWN POSITION.
82-11/3L
02/23/82
03/25/82
STEAM GENERATOR PRESSURE INDICATOR
PI-1023A READING HIGH.
82-12/3L
02/23/82
03/25/82
CHANNEL DiWIDE RANGE NUCLEAR
INSTRUMENT SPIKING HIGH.
82-13/3L
03/16/82
03/25/82
AUXILIARY BUILDING OPERATOR
INADVERTENTLY ISOLATED #21 CTMT
SPRAY HEADER.
82-14/3L*
03/04/82
04/02/82
OIL FROM #21 EMERGENCY DIESEL
GENERATOR CONTAMINATED UITH
STANDING WATER.
For the LERs selected for onsite review (denoted by asterisks above), the
inspector verified that appropriate corrective action was taken or responsibility
assigned and that continued operation of the facility was conducted in accordance
with Technical Specifications and did not constitute an unreviewed safety question
as defined in 10CFR50.59.
Report accuracy, compliance with current reporting
requirements and applicability to other site systems and components were also
reviewed.
-- 2/82-14: On March 3,1982 a 55 gallon drum of poor quality lube oil was
added to the lube oil day tank of diesel generator 21.
Prior to trans-
ferring the oil from the day tank to the diesel generator crankcase on
3/4/82 an operator obtained a sample of the oil, visually noted its
poor condition, and reported the problem to the shift supervisor. None
of the oil reached the diesel generator crankcase. The vi_sual sample was
not required by procedure. The inspector discussed this event with licensee
operations and quality assurance personnel and determined that the lube oil
is listed on the licensee's Q-list.
It is not, though, supplied to the
licensee with a vendor certificate of compliance, and only undergoes a
receipt inspection consisting of a part number comparison. The licensee's
established controls were not sufficient to verify oil quality in this
instance. The inspector pointed out to licensee personnel the requirements
of Appendix B to 10CFR50 regarding control of purchased material. He
reminded them of a January 7,1980 NRC letter to All Power Reactor Licensees
which specified that consumable items where quality is necessary for
functional perfonnance of safety related components shall also be classifieri
as safety related and thus subject to applicable provisions of Appendix B
to 10CFR50. The licensee has stated in LER 82-14/3L that BG&E will establish
a program by April 30, 1982 to sample lube oil and similar consumables
prior to use. This item is unresolved pending licensee action and subsequent
NRC:RI review (318/82-05-05).
-- 1/82-08: Onsite followup of this LER was continuing at the end of the inspec-
tion and will be documented in the next resident inspection report.
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10.
Radioactive Waste Releases
Records and sample results of the following liquid and/or gaseous radioactive
waste releases were reviewed to verify conformance with regulatory requirements
prior to release.
Gaseous Waste Permit G-16-82, Unit Containment Vent via ECCS Sump,
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released on 2/21/82. Group I release rate 5.09x102 m3/sec., Group
II release rate 2.41x10-1 m3/sec.
Release of Reactor Coolant Waste Monitor Tank 12 on 3/11/82; total
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released 1.03x10-2 curies, excluding tritium and noble gases.
Liquid Permit M-034-82, Release of Miscellaneous Waste Monitor Tank
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11 on 3/18/82; total released 1.19x10-4 curies excluding tritium and
noble gases.
(Pre-release estimate; sampling, analysis and calculations
were observed for this release.)
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Gaseous Waste Permit G-028-82, Release of Waste Gas Decay Tank 12 on
3/22/82. Group I release rate 3930m3/sec., Group II release rate 228m3 sec.
/
(pre-release calculations).
Liquid Permit R-022-82, Release of Reactor Coolant Waste Monitor Tank 12
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on 3/28/82; total released 7.39x10-3 curies, excluding tritium and noble
gases.
Gaseous Waste Permit G-032-82, Containment Vent via ECCS Sump, released
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2 m3 sec., Group II release
on 4/3/82. Groyp I release rate 1.09x10
/
rate 2.64x102 m3/sec.
A.
During the review of Permit G-028-82 the inspector noted several problems
with the format of the permit and the governing procedure.
Procedure RCP
l-604, Radioactive Gaseous Waste Permits had last been revised on
November 13. 1981. The inspector noted that the procedure directed the
calculation of a Group I and II release rate but did not specify either
administrative or Technical Specification limits for releases. The
release permit (procedure att chment 1) specified administrative limits
S
(7700 m3/sec. , Group I; 220 m /sec., Group II) and required approval of
the General Supervisor-Chemistry (GS-C) prior to exceeding these limits
The Technical Specification limits (3.85x105 m3/sec for Group I, 2x10-8
curies /sec. for Group II) were not included in the permit. The release
of Waste Gas Decay Tank 12 had been above the administrative limit for
Group II. Chemistry technicians questioned concerning their actions if a
release was above administrative limits stated that they would notify the
GS-C for approval prior to the release. The Shift Supervisor stated that
they relied on Chemistry to ensure releases were within limits. The
inspector calculated the release in question and detennined that it was
23.6% of the Technical Specification instantaneous limit (2.0 uCi/sec.).
The procedure was also noted to be confusing in that the only discussion
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relating to administrative approval by the GS-C was in the following
sentence:
"4.1.6 Determine the release rate (c) for each group where
C = fi Al _7F.
For discharge rates greater than 2.36 E-2
MPCj
3
m /sec. the approval of the General Supervisor-Chemistry is required."
The inspector noted that this was confusing in that the units (m3/sec) for
the discharge rate are the same as for the release rate which is calculated
in the same step, and no mention is made of the Administrative Limits for
release rates. The licensee stated that some of these problems had been
noted during a Quality Assurance Audit conducted the preceeding week, and
that the procedure would be revised for clarity and to incorporate
Technical Specification limits. The inspector stated that revision of
procedure RCP l-604 would be followed by the NRC (317/82-05-03).
B.
Calculations for the response of the liquid waste monitor (0-RE-2206)
during the release of Miscellaneous Waste Monitor Tank 11 were reviewed.
The calculated response of the instrument was an increase of 63 counts
per minute (cpm).
Because the background was 2000 cpm the increase was
essentially non-observable. The inspector questioned the licensee con-
cerning provisior.s to reduce the background and the accuracy of the
instrument response. The licensee stated that the background was due to
internal plate out in the monitor and that cleaning was required to reduce
the background. The licensee did not have a threshold for initiating
cleaning nor a periodic maintenance action to clean the monitor. A
review of procedure OI 17 D, Miscellaneous Waste Processing System,
revealed that provisions were included to flush the liquid waste monitor
with demineralized water following releases.
Discussions with Auxiliary
Building Operators confirmed that this was being conducted.
The inspector reviewed the calibration records for the Liquid Waste
Processing Discharge radiation monitor. 0-RI-2201, last performed on
October 12, 1981.
(FTI-ll4, Revision 4, ap
Radiation
Monitor Drawer Calibration Check Procedure) proved 8/31/79
The procedure
.
calibrated the channel and contained a check of the channel with sources
of known strength and energy levels. The calibration was performed at a
background of 4300 counts, however, the increase caused by the low source
(769countsdesign 763 counts actual) was in tolerence. The high alarm
was set at 1.75x104 counts per minute.
Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring
Programs (Normal Operations) - Effluent Streams and the Environment and
various sections in the FSAR were reviewed by the inspector to determine
licensee commitments in this area and NRC guidance. The FSAR addressed
correlaticn of the actual liquid monitor's response to the laboratory
analysis estimated response. This correlation would allow the licensee
.
,
,
.
19
to periodically relate monitor readings to the concentrations and/or
release rates of radioactive materials in the release path. Regulatory
Guide 4.15 also addressed such a correlation and provided an acceptable
method for detemination of background counting rates and trending these
rates on a control chart for action when the measurement value falls
outside the pre-determined control values. The licensee stated that it
had been several years since a correlation had been perfomed. The licensee
committed to perform a correlation for the liquid waste monitor and establish
appropriate measures to control the background counts of the instrument to
allow better monitoring of liquid wastes. This item is unresolved (317/
82-05-04; 318/82-05-05).
C.
Inspection Report 317/82-02; 318/82-02 dated Februcry 16, 1982 contains
two typographical errors. The following correction should be made on
page 6, section 6 of the report:
12 Reactor Coolant Waste Monitor Tank, released 1/7/82,
-
expected release 7.08 E-3 curies, excluding tritium and
i
i
noble gases.
4
12 Reactor Coolant Waste Monitor Tank, released 1/11/82,
-
expected release 1.64 E-5 curies, excluding tritium and
noble gases.
11.
IE Bulletin Followup
The inspector reviewed licensee actions on the following IE Bulletins (IEBs)
to determine that the written response was submitted within the required time
period, that the response included the infomation required including adequate
corrective action commitments, and that licensee management had forwarded copies
of the response to responsible onsite management. The review included discussions
with licensee personnel and observations and review of items discussed below.
,
--
IE Bulletin 80-06, ESF Reset Controls. This bulletin had previously been
inspected (Inspection Reports 317/80-16; 318/80-15; 317/81-07; 318/81-07;
317/82-05; 318/82-05), including review of responses to the NRC, scope of
actions and testing, and observations of testing. A revised response
was requested addressing the completion of revised testing and describing
the actual resets tested in accordance with the bulletin. This response
was sent to the NRC in a letter dated March 11, 1982, and was reviewed.by
the inspector. No unacceptable conditions were identified and IEB 80-06
is closed.
12. Review of Periodic and Special Reports
,
Unon receipt, periodic and special reports submitted pursuant to Technical Specification 6.9.1 and 6.9.2 were reviewed. That review included the following:
Inclusion of information required by the NRC; test results and/or supporting
information consistency with design predictions and performance specifications;
planned corrective action adequacy for resolution of problems; determination
whether any information should be classified as an abnormal occurrence; and
validity of reported infomation. The following periodic report was reviewed:
>
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February,1982 Operations Status Reports for Calvert Cliffs No.1
Unit and Calvert Cliffs No. 2 Unit, dated March 15, 1982,
13. Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable. Unresolved items are discussed in
paragraphs 4, 9, and 10 of this report.
14.
Exit Interview
Meetings were held with senior facility management periodically during the
course of this inspection to discuss the inspection scope and findings. A
summary of findings was also provided to the licensee at the conclusion of
the report period.
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