IR 05000317/1984099: Difference between revisions

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{{Adams
{{Adams
| number = ML20202E225
| number = ML20210S304
| issue date = 06/11/1986
| issue date = 09/25/1986
| title = SALP Repts 50-317/84-99 & 50-318/84-99 for Oct 1984 - Apr 1986
| title = Confirms Scheduled Mgt Meeting on 861008 at Region I Ofc Re Util Presentation Concerning Forthcoming Outage Per Recommendation of SALP Repts 50-317/84-99 & 50-318/84-99. Meeting Agenda Requested by 861003
| author name =  
| author name = Kane W
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name =  
| addressee name = Tiernan J
| addressee affiliation =  
| addressee affiliation = BALTIMORE GAS & ELECTRIC CO.
| docket = 05000317, 05000318
| docket = 05000317, 05000318
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-317-84-99, 50-318-84-99, NUDOCS 8607140308
| document report number = NUDOCS 8610080081
| package number = ML20202E214
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 62
}}
}}


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.g SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NO. 50-317/84-99; 50-318/84-99 BALTIM0RE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT ASSESSMENT PERIOD: OCTOBER 1, 1984 - APRIL 30, 1986 BOARD MEETING DATE: JUNE 11, 1986 l
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SUMMARY
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TABLE 3 - VIOLATIONS SUMMARY
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TABLE 4 - LISTING OF LERS BY FUNCTIONAL AREA TABLE 5 - LER SYN 0PSIS TABLE 6 - UNPLANNED TRIPS AND OUTAGES TABLE 7 - SUMMARY OF LICENSING ACTIVITIES ATTACHMENTS ATTACHMENT 1 - TIME SHUT DOWN PER MONTH IN DAYS ATTACHMENT 2 - TOTAL NUMBER OF SHUTDOWNS AND TRIPS PER YEAR SINCE STARTUP (UNITS 1 AND 2)
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I. INTRODUCTION Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations and data on a periodic basis and to evaluate licensee performance based upon this in-formation. SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant operatio The NRC SALP Board, composed of the staff members listed below, met on June 11, 1986 to review the collection of performance observations and data to assess licensee performance in accordance with guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."
 
A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety per-formance at the Calvert Cliffs Nuclear Power Plant for the period October 1, 1984 through April 30, 1986. It is noted that the summary findings and totals reflect a 19 month assessment perio , SALP Board Members Board R. W. Starostecki, Director, Division of Reactor Projects (DRP) and Chairman E. C. Wenzinger, Chief, Reactor Projects Branch 3, DRP L. Tripp, Chief, Reactor Projects Section 3A, DRP T. Foley, Senior Resident Inspector, Calvert Cliffs NPP D. Jaffe, Licensing Project Manager, NRR A. Thadani, Director, PWR Directorate #8, NRR W. Johnston, Deputy Director, Division of Reactor Safety J. Joyner, Chief, Nuclear Materials Safety and Safeguards Branch, Division of Radiation Safety and Safeguards Attendees D. F. Limroth, Project Engineer, DRP D. C. Trimble, Resident Inspector, Calvert Cliffs NPP
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4 C. Background Licensee Activities Unit 1 At the beginning of the period the unit was operating at full powe On October 2, 1984, the unit was manually tripped due to the reduc-tion of main circulating water flow caused by an accumulation of jellyfish on intake structure traveling screens. During plant re-start, a Reactor _ Coolant System (RCS) over cooling event occurred which was principally caused by operator error in over feeding steam generator RCS pressure dropped to 1775 psig. The unit returned to power on October On November 20, 1984, Unit I was again manually tripped due to an influx of jellyfish on intake screen Following the trip, an ex-traction steam line ruptured filling the turbine building with steam and causing first degree burns to one individual. The unit returned to power on November.2 On November 29, the unit was shut down to repair a flex hose on Reactor Coolant Pump #118 pressure sensing line and a pressurizer sample valve. Power operation resumed on December On December 12, the unit was shut down to repair hydraulic system ,
leakage on #11 Main Steam Isolation Valve (MSIV). During the shut down, #12 MSIV failed to shut completely. MSIV #11 was repaired and MSIV #7.2 successfully cycled (however cause of original failure of MSIV #12 was not positively identified). Power operation resumed on December 2 On January 16, 1985, Unit 1 was shut down to repair safety injection tank check valve back leakage problems. During the shut down, the root cause of previous #12 MSIV problems was identified and cor-rected. The unit was restarted on January 19. On February 5, Unit 1 tripped on low steam generator level caused by operator error in opening a wrong breaker which resulted in a loss of main feeder pump Power operation was quickly resume Unit 1 commenced its Cycle 7 refueling outage on April 6. On !iay 14, an interpolar connecting bar in diesel generator #11 broke free and caused damage to stator windings. That generator was ultimately replaced and similar bars were' removed from the remaining diesel generators. The Unit 1 outage was extended to July 30 due to iden-tification of damaged insulation in the main turbine generato During restart, the shaft seal for #11 B RCP failed and the outage was extended to August 6. Three trips occurred during start up (high moisture separator reheater level caused by mispositioned valve, low steam generator trip due to operator error, and a trip due to improperly adjusted main turbine thrust bearing wear detec-tor).
 
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On September 30, and again on October 3, the unit tripped due to a DC system ground which caused spurious high main feed-water heate level indications to the main turbine protection syste Power operation was resumed and continued until October 9, when a shut down was initiated to repair a cracked RCP bleed off line. While on shut down cooling, 500 gallons of RWT water leaked into contain-ment through the containment spray header due to a incomplete valve closure. Power operations resumed on October 1 On January 23, 1986, the unit tripped due to a malfunctioning of a Reactor Trip Breaker during surveillance testing. It was re-started on January 24. From March 17-24, the unit was shut down to repair a degraded RCP seal and a leaking pressurizer relief valve. Power operation was then continued through the end of the perio Unit 2 Unit 2 began the period operating at full power. On October 3, 1984, the reactor tripped on low steam generator water level due to the loss of #22 main feed water pump (cause of pump trip not positively identified). buring plant restart, a series of personnel and equipment problems occurred nearly simultaneously (main steam safety valve stuck partially open, two control rod drops (same rod),
a turbine bypass valve stuck shut then inadvertently opened, in-advertent isolation of a atmospheric steam dump valve). Power operation was resumed on October The unit was manually tripped on April 25, 1985 following indication that two shaft seals had failed on a reactor coolant pump (RCP).
 
The plant was restarted on May 5; however, the reactor tripped on low RCS flow during power ascent due to a loss of #21 RCP (faulty relay caused breaker to trip). Power operation resumed on May The unit was shut down from May 18 to May 22 to inspect and replace pressurizer spray valve fasteners. On May 23, with the unit at 100%
power, an inadvertent Recirculation Actuation Signal (RAS) occurred due to technician error. No plant transients were induced.
 
. On July 24, Unit 2 was shut down to repair steam leaks on a cold reheat steam line. During this shut down, #21 MSIV failed to fully close. Troubleshooting and repair activities took until August The unit began its sixth refueling outage on October 1 During
: the plant startup in early December, RCF #21 A seal became degraded,
; and the outage was extended through December 10, 1985. On December i
12, the unit tripped on low steam generator water level due to the loss of #21 MFW pump (erroneous control signal). On February 4,
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1986, the unit tripped for no apparent reason. The cause of the trip was never identifie Power operation resumed on February 5 and continued through the end of the period.
 
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2. Inspection Activities Two NRC resident inspectors were assigned during the inspection period. The total NRC inspection effort for the period was 5258 hours (resident and region based) or an average of 3312 hours per year with a distribution in the appraisal functional areas as shown in Table 2 (Inspection Hour Summary).
 
During the period, NRC team inspections were conducted of the fol-lowing areas: Actions taken relative to IE Bulletins 79-02, 79-04, 79-07, and 79-1 Equipment Qualification (2 inspections). Special inspection of equipment and activities identified in
"Calvert Cliffs Probabilistic Risk Assessment Dominant Se-quences" as important to prevent or mitigate severe accident NUREG 0737 item implementation (Post Accident Sampling System, Containment Radiation Monitors, Noble Gas Effluent Monitor, and In Plant Radio-Iodine Measurements). A team inspection of Post Accident Sampling Syste Operator Requalification Progra IE Bulletin 80-11, Masonry Wall Desig An NRC Emergency Preparedness inspection team observed the annual emergency exercise on September 10, 198 Tabulations of Inspection Activities and Violations are attached as Tables 1 and 3, respectivel This report also discusses " Training and Qualification Effectiveness" and " Assurance of Quality" as separate functional areas. Although these topics, in themselves, are assessed in the other functional areas through their use as criteria, the two areas provide a synopsi For example, quality assura,ce effectiveness has been assessed on a day-to-day basis by resident inspectors and as an integral aspect of specialist inspections. Although quality work is the responsi- l bility of every employee, one of the management tools to measure this effectiveness is reliance on quality assurance inspections and audits. Other major factors that influence quality, such as involve-ment of first-line supervision, safety committees, and work atti-tudes, are discussed in each are The topic of fire protection is not discussed as a separate func-tional area because of insufficient inspection activity. The avail-able observations on fire protection and housekeeping are included in the various relevant functional area .
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II. CRITERIA Licensee performance is assessed in selected functional areas. Each functional area represents areas significant to nuclear safety and the environment, and are normal programmatic areas. The following evaluation criteria were used to assess each are . Management involvement and control in assuring qualit . Approach to resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement histor . Reporting and analysis of reportable event . Staffing (including management). Training effectiveness and qualificatio However, the SALP Board is not limited to these criteria and others may have been used where appropriat Based upon the SALP Board assessment each functional area evaluated is clas-sified into one of three performance categorie The definitions of these performance categories are:
Category 1: Reduced NRC attention may be appropriat Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety is being achieve Category 2: NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and concerned with nuclear safety; licensee resources are adequate and reasonably effective such that satisfactory performance with respect to operational safety is being achieve Category 3: Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear strained or not effec-tively used such that minimally satisfactory performance with respect to operational safety is being achieve The SALP Board also assessed each functional area to compare the licensee's performance during the last quarter of the assessment period to that during i
the entire period in order to determine the recent trend for each functional area. The trend categories used by the SALP Board are as follows:
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Improving: Licensee performance has generally improved over the last quarter of the current SALP assessment perio Consistent: Licensee performance has remained essentially constant over the last quarter of the current SALP assessment perio Declining: Licensee performance has generally declined over the last quarter of the current SALP assessment perio .
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III. SUMMARY OF RESULTS Facility Performance Category Category Last Period This Period (10/1/83- (10/1/84- Recent Functional Area  9/30/84) 4/30/86) Trend * Plant Operations  1 2 Consistent Chemistry and Radiological Controls 1 1 Consistent Maintenance  2 2 Consistent Surveillance  2 1 Consistent Emergency Preparedness  1 1 No Basis Security and Safeguards  1 1 Consistent Refueling, Outage Management and Engineering Support  1 2 No Basis Licensing Activities  1 1 Consistent Assurance of Quality  N/A 2 No Basis Training and Qualification Effectiveness  N/A 2 Consistent
* Trend during the last quarter of the assessment perio Overall Facility Evaluation The recent organization has had significant positive impact by providing increased management attention in all areas. Management support and resources are made available to correct recognized problems in a timely fashio Numerous management programs continue to demonstrate the lic-ensee's pursuit of quality, regulatory compliance, and efficient opera-tions. Programmatic weaknesses were noted in the timeliness in which potential safety issues are recognized, lack of effectiveness in solving recurring problems in the Instrumentation and Controls area with a re-sultant effect on reactor operator performance, and the inadequate or-chestration of multi-discipline tasks in that responsibility and author-ity are not vested in individuals in such a manner to ensure effective task completio .
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In several instances, the licensee was slow to recognize the existence of potential safety issue Extensive NRC involvement was required be-fore thorough licensee actions were taken. In other instances, an ex-cessive number of similar events occurred (e.g., reactor trips) before thorough licensae investigation, evaluation, and resolution of root cause(s). POSRC effectiveness was not demonstrated in that root cause identification rad adequate problem resolution was not always required for POSRC concurrence. NRC often felt the need to question proposed ac-tions, suggest additional actions, and generally become directly involved in a manner normally expected of licensee management and POSRC to achieve adequate resolution of potential safety issue A number of reactor trips and forced outages occurred in both units due to causes that appeared to be maintenance and design related. Other trips were due to personnel errors or were precautionary in nature as a result of maintenance / design related problems. Most trips due to such causes should be avoidable; however, the licensee had little success in reducing the frequency of such trips on either unit during the entire SALP perio . - . - - - . _ . -. . .__ - - - _
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IV. PERFORMANCE ANALYSIS Plant Operations (1295 hours, 24.6%) Analysis
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The previous SALP determined the operations area to be Category It concluded that additional management emphasis was needed to (1) properly evaluate temporary changes (pursuant to 10 CFR 50.59)
!  to the facility prior to implementation and (2) improve the effec-4  tiveness of the Plant Operations and Safety Review Committee (POSRC).
 
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That committee had been slow to recognize the potential safety sig-i  nificance of major salt water system corrosion problems. 10 CFR
:  50.59 evaluations have improved. However, although attempts have been made to improve POSRC effectiveness, significant problems con-tinue to exist. Untimely recognition of potential safety issues
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and inadequate analysis for the identification and resolution of root causes of plant trips, ESF actuations, and other safety related i  problems persist. Inadequate root cause analysis was demonstrated
]  by recurring Main Steam Isolation Valve (MSIV) inoperability prob-lems becuase of failure to identify the root cause after the first
;  event (see Maintenance functional area). Additionally, repeating i  plant trips resulted from feed pump control and feedwater heater level circuit problems. Again, root cause analysis was deficient after the initial and often after the second event (see Table 6 for
]  trips occurring on 10/3/84, 9/30/85, 10/2/85, 12/12/85, and 2/4/86).
 
An excessive number of events often have occurred before the licen-
!  see will dedicate sufficient time and resources to identify the root 4  caus ,  NRC involvement was necessary to heighten licensee awareness of
!  potential safety concerns to a point where corrective action was i
initiated or, where necessary, accelerated. While some instances of this are to be expected, the relatively large number of occur-rences during this SALP period indicates that a weakness exists in the licensee's process of screening for potential safety question Specifically, NRC involvement was necessary to: (1) obtain in-cubicle
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testing of reactor trip breakers; (2) conduct further troubleshoot-i  ing of a main steam isolation valve; (3) conduct further trouble-shooting of main steam safety valves; (4) adequately evaluate ef-
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fects of a possible cavity seal failure; (5) adequately evaluate
,  the use of belzona in repairing salt water system piping; and
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  (6) initiate improvements within the Emergency Diesel Generator rooms. Notwithstanding this weakness, it should be pointed out that
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almost without exception, once the licensee fully recognizes the
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existence of a potential safety problem, they ensure that the root
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cause is identified and thoroughly resolved. An example of this
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was the troubleshooting and repair of a second main steam isolation
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valve. Plant management elected to maintain the plant shutdown to
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tics) even though some evidence existed that the valve might be considered operabl !    During the 19 month period, three reactor trips (2/1/85, 8/6/85, i
and 8/8/85) were attributable to operator performance; operating j    the wrong IAC circuit breaker (Instrument AC instead of Instrument i
Air Compressor) resulted in a turbine / reactor trip, feilure to com-i    ply with the tagout control procedure resulted in a mispositioned
;    valve and a turbine / reactor trip, and operator error in maintaining
!    steam generator water level with a positive reactivity temperature
;    coefficient. One SGIS actuation was caused by operators failing i    to block the signal in accordance with procedure during cooldow Operators acted promptly and effectively to avoid several plant i    trips due to malfunctioning air compressor components, and acted
;    prudently in initiating precautionary plant trips on 4/25/85 and j    10/2 and 11/20/84 due to indication of a reactor coolant pump seal
;    failure, and severe aquatic fouling of intake structure screens.
 
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Some weakness was noted in the extent of control room operator l    knowledge of ongoing maintenance activities, including the potential j    impact those activities might have on plant operation. Additional
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weaknesses were noted in the interfaces between the operations and chemistry groups (e.g., containment isolation sample valves left i    open and sample sink left in recirculation mode without operator i
knowledge) and between the chemistry and licensing groups (e.g. who i    failed to communicate information on what constituted the primary I    and backup post accident sampling systems and failed to ensure the
!    chemistry group was aware of a new surveillance requirement for the
;    noble gas monitoring system).
 
I j  Two losses of shutdown cooling occurred due to inadequate main-j    tenance/ test procedures. A recent AE00 report pointed out that the j    licensee has had a significant history of losses of shutdown coolin j  A growing number of problems with control board indications (i.e.,
j    approximately 75 MRs per unit) hinder the plant operators' ability j    to monitor _and react to plant conditions.
 
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The licensee placed strong emphasis on prior planning. Division and department goals / objectives were clearly stated and widely dis-
 
seminated in the form of a " Nuclear Energy Program Plan." They were j    directed toward improved performance versus maintaining status quo
!    and addressed the areas of public safety, personnel safety, eco-i    nomic performance, productivity enhancement, and external perception.
 
{    An Integrated Management System (IMS) has been implemented which j    provides a systematic method for prioritizing plant betterment and
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regulator identified projects by development of benefit to cost
:    ratios. IMS is intended to provide a meaningful basis for negoti-
!  ating implementation schedules with the NRC and a means for managing I
an integrated work plan for the sit It is closely coupled to the
;-  Nuclear Energy Program Plan.
 
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Fire Protection, personnel safety, and housekeeping continued to receive strong emphasis. With few exceptions, housekeeping was excellent, and contamination control was good. The diesel genera-tors, formerly a problem area due to significant accumulations of oil and grease on and under the engines, underwent upgrades to cor-rect sources of oil leakage and were cleaned and painte The operations group took a lead role throughout this period in the area of coordinating maintenance and operations activities. They helped set maintenance priorities, optimize scheduling, tag equip-ment out of service at the proper time, and ensured post maintenance testing was accomplishe They improved their guidance on what specific post maintenance tests were required for various types of maintenanc On January 1, 1986, major organizational changes were implemented which allowed full involvement of upper level company management in nuclear activitie Nuclear activities were separated from fos-sil and gas departments and placed under the direction of a vice president dedicated to nuclear operations. Three additional manager level positions were created on sit As part of the company re-organization, QC functions which had been previously assigned to the QA department were transferred to line departments. This was done to provide line supervisors with a tool to ensure work was being accomplished correctly under the philosophy that quality is a line function (see Assurance of Quality Functional Area). This action brought a compliment of QC personnel to the operations de-partment. Due to the timing of these recent changes, it has not been possible to evaluate their effectivenes Staffing and training levels within the operations group were ex-cellen The licensee continued to display a strong commitment toward licensed operator training as evident by a high success rate in passing NRC Reactor Operator (RO) and Senior Reactor Operator (SRO) examination Annual written requalification examinations were administered to 29 SR0s and 25 R0s in which 1 SR0 and 1 RO failed, who were subsequently re-examined successfully. Three NRC administered examinations were successfully passed upgrading R0 licenses to SR0 licenses. A Training Effectiveness Inspection was conducted pursuant to Regulatory Guide 1021 in which 2 SR0s and 4 R0s of one shift crew received NRC written and oral examinations; 3 SR0s and 2 R0 operations staff workers received just an oral ex-amination and another 3 SR0s and 2 R0 staff workers received'a written examination. Two individuals failed the written examination, but were subsequently re-examined successfully. No generic weak-nesses were noted during the inspection. The licensee maintained 69 current licenses, 38 SR0s and 31 R0s. Discussions with licensed operators indicated that the training staff was responsive to their input, and that training improved in quality with the advent of new site specific simulator in January 198 Formally, the simulator
 
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began operation in September 1985 with symptom based Emergency Operating Procedure training. Simulator training was preceded by meetings between the operations crew shift supervisor and the simu-lator instructo This provided operations input and tailored each class to specific perceived weaknesses as well as the requisite trainin '
The operations training program had an in progress task analysis
;  to define the specific skills of the operator. This job task an-alysis was being combined with INP0's requirements and NRC's KSA Catalog (Knowledge, Skill, and Abilities).
 
,  In summary, the Operations Department provided excellent prior main-tenance planning and logical assignment of priorities. Conservatism was routinely exhibited after a potential safety issue was recog-i
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nized. There were few long standing regulatory issues. Weaknesses were noted in operator awareness and possible effects of ongoing plant maintenance and personnel errors contributing to reactor trips, ESF actuations and losses of shut down cooling. A signifi-cant weakness was noted in the apparent reluctance to perform a thorough diagnostic assessment for true root cause of events in a timely fashion and excessive reliance on NRC involvement before potential safety issues were recognized and adequately pursue . Conclusion Rating:  Category 2.
 
l  Trend:  Consisten . Board Recommendation Licensee Increase management attention to more aggressively recognize poten-tial safety issues and to improve the root cause analysis of prob-
,  lem NRC None.
 
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8. Chemistry and Radiological Controls (901 hours, 17%) Analysis There were fourteen inspections conducted by radiation specialists during this period. The inspections examined the licensee's radi-ation protection program, radioactive waste management and effluent
; controls, environmental monitoring program, and transportation of radioactive material. A team inspection of Post Accident Sampling Systems and a non-radiological chemistry program review were also performed. Resident inspectors monitored the implementation of the radiation protection programs, as well. There were four Licensee Event Reports (LERs) in the Radiological Controls area during this assessment, the same number as in the previous assessment perio However, they were not repetitiou The radiological protection program was well staffed with highly
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qualified and trained personnel. Particular program strength was evidenced by the high quality performance of the radiological con-trols staff in several program areas, including the ALARA program, and controls during the conduct of high exposure operation Facilities and equipment were well maintained with excellent per-formance records, including the new material processing facilit This new facility provided for well controlled and timely mainten-ance, testing and inspection of respirator protection equipmen This contributed to a high quality respirator protection progra Due to fully qualified staff and well designed facilities, a strong program for handling, storage, and segregation of radioactive waste l was in place. The equipment, facilities, and operations of the whole body counting facilities were particularly impressiv Using these facilities, the licensee measurements of the NRC provided phantom were in full agreement with the type and quantities of
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isotopes in the phanto The ALARA program was strong and effective with good management support. ALARA reviews of planned work was thorough and revaluation of work in progress was excellent. During the course of several inspections in this rating period, the ALARA program was examined and found to be commendabl l The licensee's ALARA person-rem goal for the site was 720 for 198 The total exposure for 1985 was 648 person-rem. During 1985 signi-
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ficant radiological operations occurred including two refueling outages. An aggressive ALARA person-rem goal (upper limit) for 1986
. was established at 391 person-rem for the site. By the end of this
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assessment period, only 13% of the limit had been experienced. This
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was due to the licensee's management commitment to effectively re-j duce radiation exposure, l
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The external and internal exposure control programs were well founded and technically sound. These programs were supported by clearly defined policies and procedures. However, non recurrent violations were identified by NRC including failure to follow pro-cedures, exposure records keeping, and lack of a detailed procedure for the standup whole body counter. These were infrequent minor problems and not indicative of any substantial program weaknes The radiation controls Quality Assurance audits were performed in a timely and comprehensive manner. Correction of audit findings was timely and technically soun The licensee implemented an effective radioactive waste management progra Licensee personnel at all levels in the radwaste opera-tions were very knowledgeable with regard to their functions and responsibilitie No problems were identifie On going training was eviden Based on an inspection conducted October 1985, the licensee did not have a program that included implementing procedures for identifying, sampling, and analyzing the various waste streams to assure compli-ance with 10 CFR 61, even though a program was required after December 27, 198 The licensee performed periodic audits of the transportation progra The audits were performed in accordance with the requirements of Part 50, Appendix B. However, the frequency of auditing criteria applicable to transportation of radioactive waste was not specific-ally establishe The licensee had adequate chemistry and radiochemistry program The licensee met Technical Specification requirements for in plant and effluent sampling and analysis, and, in particular, the licensee met their new Radiological Effluent Technical Specifications (RETS),
which were implemented on July 1, 1985. Review of the licensee's implementation of the RETS noted a lack of thoroughness in some area For example, surveillance procedures had not been formalized for monitor calibration, training was not well documented and records of procedure change for the liquid discharges were not availabl During the assessment period, an inspection was conducted using the NRC I Mobile Radiological Measurements Laboratory. All in plant and effluent samples split between the licensee and the NRC during this inspection were in agreement. Minor follow up items were identified during this inspection that indicate a lack of initiative by the licensee to make constant improvements in the program in order to maintain and improve the quality of the analytical meas-urements. These items included the quality control of radiochemical measurements including lack of participation in any interlaboratory comparions, use of control charts, and other control statistic .
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Weaknesses identified in the non-radiological chemistry program were eliminated and toward the end of the SALP period, significant im-provements in the controls of analytical measurements were achieve NRC inspections identified significant deficiencies in the Post Ac-cident Sampling System (PASS). A failure of the on site chemistry group to assign sufficient priority to the operation of PASS led to a number of these deficiencies (e.g. Inadequale procedures and system dilution factors not determined). However, causal factors external to the chemistry group were also involved. PASS problems are therefore more fully addressed in the Refueling Functional Area of this repor In summary, only minor problems were identified regarding personnel exposure controls and technical specification surveillances for plant ventilation system . Conclusion Rating: Category Trend: Consisten . Board Recommendation Licensee Non NRC Non .
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C. Maintenance (837 hours, 16%) Analysis The previous SALP identified problems with (1) recurring equipment deficiencies, (2) insufficiently aggressive program to assess and correct salt water system corrosion problems, (3) and weak post modification follow up (insufficient controls for ensuring oper-ability and priority for repair as well as lack of support by the the installing organization) for TMI action plan items. Addition-ally, a concern was raised whether equipment qualification was being adequately considered in the maintenance program. A summary of licensee performance in these areas is described belo Resolution has been achieved on most of the material problems noted in the last SALP report. Problems with charging pump packing leak-age and SGFW pump control continue Charging pump packing was a concern because tt.e licensee recently took credit for these pumps in their safety analysis. Barton pressurizer pressure transmitter drift problems were still occurring, but at a reduced rat Barton had not provided an acceptable resolution, and the licensee was asking another vendor to develop and provide a substitute transmit-te During the interim, Barton transmitter performance was rou-tinely monitored to detect drif A large program was ongoing regarding salt water system corrosion problems. The thorough corrective action program for components susceptible to graphitic corrosion was on track. A number of those components had been replaced (e.g., component and service water' heat exchanger channel heads), and plans were underway to replace others (e.g., salt water pump casings). Improved inside wall coatings and cathodic protection were being used. A general problem still ex-isted with wall thinning and periodic occurrence of small, through-wall holes in carbon steel piping, where the cement-mortar protec-tive lining had eroded or broken away. This leaves the bare metal directly exposed to the corrosive effects of saltwate A program was ongoing to replace piping in high turbulent flow areas with rubber lined pip NRC inspections during the period disclosed significant deficiencies in the installed Post Accident Sampling System (PASS). These de-ficiencies are described and included in this assessment in the Re-fueling Outage Management functional Area of this report. Finally, during the period, a program to include equipment qualification re-quirements in maintenance activities was implemented. Further de-tails on licensee performance in equipment qualification areas is also provided in the Refueling and Outage Management Functional Area where its impact on this assessment is considere .
b
 
The recent company reorganization described in the operations sec-tion brought increased management attention to the maintenance are As a result of an in depth review of the maintenance program, major changes and enhancements of existing programs were being initiated: Implementation of the systems engineer concep . Creation of a centralized planning and scheduling group that provided improved coordination within the maintenance depart-ment and with the Operations Departmen . Improvements in training program . Joint effort with the Electric Power Research Institute (EPRI)
to upgrade design and performance of valve packin . Establishment of a " roving" maintenance crew on the back shift to support post maintenance testing and to conduct minor main-tenance activities. This program has proven effective in reducing the number of outstanding maintenance request The licensee made major changes in the Quality Control (QC) are Maintenance QC functions were transferred to the Maintenance De-partment. An enhanced cross training program was initiated to im-prove QC inspectors knowledge and skills and maintenance personnel's knowledge of the quality control philosoph Notwithstanding the above, the following problems were identified: During the period, weaknesses were noted by the NRC in the qualification program for maintenance personnel assigned re-sponsibility for Reactor Coolant Pump (RCP) seal rebuildir;.
This coupled with seal performance problems in service cr.Jsed the licensee to organize a RCP shaft seal task force to review seal performance, training of maintenance personnel, quality of spare parts, operating practices, and maintenance procedure . Problems were noted in the area of maintenance procedure Two losses of shutdown cooling events resulted from inadequate procedures by the Instrument and Control Department. The lic-ensee exercised the option of omitting detailed steps from procedures when the task was considered within the knowledge, skills, and abilities of the worke Additionally, certain temporary modifications (lifted wire / temporary jumpers) were exempted from screening for unreviewed safety questions when accomplished and restored within one shift. In combination, the option of omitting detailed steps in maintenance procedures and the exclusion of reviews of certain temporary changes has
  ...  - -
 
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18 led to abuse and allowed work on safety related systems without adequate screening for possible effects. Procedure writing groups were appointed and were rewriting / revising procedure More than two hundred maintenance related procedures were improved through such efforts during this assessment perio . Following an incident where pressurizer spray valve fasteners failed due, in part, to over torquing, the licensee embarked on an extensive program to improve training and controls over fastener torquin . Problems due to main feedwater pump speed control circuity possibly due to electrical grounds and/or component failures led to two plant trips during the SALP period and two addi-tional trips immediately following the period. Electrical grounds on feedwater heater level control circuity caused two automatic plant trips. Additional maintenance problems led to u.nplanned trips and outages and included: safety injection tank check valve leakage, a main steam isolation valve hydraulic oil system leak, and an improperly adjusted thrust bearing wear detector. The cause of one trip late in the SALP period was unidentified but may also have been due to an electrical ground problem. The licensee willingness to " live with" ground prob-lems prompted trore active NRC involvement to effect problem resolutio Although the corrective maintenance backlog was relatively low at 600 Maintenance Requests (MRs) or 5 man weeks, numerous MRs accumu-lated on each unit's control board (75 on each). Each MR was evaluated with respect to its effect on the system. However, no evaluation was done on the total effect of the sum, nor was a limit established before a concerted effort was devoted to reducing the shear volume of MRs/ problems with the control boards. Most of these MRs were related to the I&C Department. Further, several plant trips were apparently caused by poor maintenance (see Table 6).
 
Several trips were repetitive due to a lack of thorough understand-ing of the control systems (see trips dated October 3, 1984, Sep-tember 30, 1985, and December 12, 1985). Together, the backlog of I&C related MRs on the control boards and related plant trips with-out sufficient control eystems expertise indicates a weakness in this segment of maintenance, and contributes to confusion and im-paired performance by the reactor operator Despite the licensee's efforts to miniraize rework and to identify root causes of problems, their approach to the resolution of prob-lems differed with each occurrence. There was no pre planned standard approach that was well laid out, nor any set group of per-sonnel that had experience in problem solving. Troubleshooting efforts appeared to be overly limited to the perceived most likely
 
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causes to the exclusion of others. Because of this the approach to resolution of several technical issues was less than thorough and progressed at times in an impulsive fashio The licensee has the capability to thoroughly evaluate and satis-factorily resolve problems once they are focused and committe The plant nuclear engineering group (part of the maintenance de-partment) worked very effectively with the General Supervisor Operations in resolving three equipment problems (two main isolation valve issues and main steam safety valve setpoint drift problems).
 
In summary, several of the material problems identified in the pre-vious SALP have been correcte Continued effort is still required to fully resolve main feed water control, salt water system corro-sion, charging pump packing, Barton transmitter, reactor coolant pump seal, and steam piping erosion / movement / support problem The l reorganization strengthened the Maintenance Department by placing a manager on site who was the previous plant superintendent. In-creased resources were being devoted to this area. The establish-ment of the systems engineer concept and other innovations have the potential for improved performance in this area. Major changes were already evident, i.e., diesel generator up keep, condensate area clean up, and roving maintenance crew reduction of maintenance backlog. Procedure development and training programs resulting from task analyses were in progress. Additional I&C engineering support is needed because of weaknesses in the staffing, direct line super-vision, vendor support, and spare parts areas. Increased screening of maintenance activities for possible unreviewed safety questions is neede . Conclusion Rating: Category Trend: Consisten . Board Recommendation Licensee:
Evaluate impact of secondary system maintenance problems on reactor trips (frequency, cause). Determine if poor maintenance and/or de-sign weaknesses are contributing to balance of plant related trip NRC:
Conduct meeting with licensee to discuss their trip reduction pro-gram ef forts.
 
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D. Surveillance (885 hours, 16.8%) Analysis The resident inspectors examined surveillance activities as part of the routine inspection program. Surveillance procedures related to specialized areas of inspection were reviewed during thirteen inspections conducted by region based personne The previous SALP noted that NRC inspections had identified a sig-nificantly high number of administrative and technical deficiencies in surveillance test procedures (STP's). An in depth QA auditing effort was conducted by the licensee to correct problems of this nature by ensuring that (1) STP's adequately accomplish all Techni-cal Specification surveillance requirements, (2) systems are pro-perly restored to proper alignment following STP's, and (3) sur-veillance tests are properly documented. There were two instances of deficient procedures during this period. One led to an initi-ation of an Engineered Safety Features Actuation syste A second resulted in missed survelliance tests on two control room ventila-tion dampers. The reduced rate of occurrence indicates that the quality of test procedures as a whole has improved. The control room damper problem was recurrent from the last SALP period indi-cating that initial corrective actions for that system were not sufficient to recognize remaining deficiencie The number of missed / late surveillance tests was reduced from a total of four last SALP period to one during this perio NRC inspections covered a broad cross section of surveillance acti-vities. In general, procedures were found to be clear and techni-cally sufficient; and testing was accomplished in accordance with procedures by appropriately qualified personnel. Workers performing those tests appeared knowledgeable of the systems and testing re-quirement QC/QA involvement was evident. Surveillance activities for the following areas were included within the scope of these in-spections: plant mechanical and electrical systems, containment leak rate testing, in service inspections, environmental monitoring, radioactive effluent monitors, refueling, snubber program, control room habitability, ventilation filter testing, and chemistry samp-lin The licensee continued the practice of conservatively entering Technical Specification action statements when equipment was under-going surveillance test This assured operator awareness of plant status and discouraged maintenance on redundant trains that could cause degraded condition . -
,
g  n*
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21 Management planning was evident in the area of In Service Inspec-
_ tions (ISI). A majority of the system ten year hydrostatic tests requirements were completed in advance of the upcoming ten year ISI refueling outage '
'
The licensee conducts surveillance programs which go beyond minimum Technical Specification requirements relative to steam generator (SG) integrity and primary chemistry. They took an active role in industry efforts'in these areas. A steam generator task force was organized by the licensee to monitor eddy current testing, chemistry hide'out, condenser air in leakage, steam generator lay up condi-
-tions, sludge-lancing, and abnormal chemistry trends. During out-ages the' licensee consistently performed eddy current testing on more than the minimum number of SG tubes required by Technical Specification The recent company reorganization necessitated changes in surveil-lance program responsibilities. A weakness was noted in that a plan for reassignment of surveillance responsibilities was not developed prior to the reorganization. At the close of the SALP period, the surveillance program continued to function under the previously as-signed coordination staf An unplanned outage was caused by pinhole steam leaks in a turbine cold reheat steam line. Two inadvertent Engineered Safety Features
^
System actuations were caused as a result of surveillance activities (one due to personnel error and one due to inadequate procedure).
 
The-licensee has experienced a significant problem with an increas-ing trend of low pressure steam line leaks / ruptures. These leaks have been apparently due to erosion of carbon steel pipe due to moisture saturated / low pressure steam. Although the licensee has
-
devoted considerable effort toward prioritizing and conducting sur-veillance of pipe wall thickness and replacing thinned piping, the problem is not resolved and is possibly expanding. Many areas of piping have ~not yet been inspected and leaks continue to occu A more aggressive program is needed to stay ahead of the proble In summary, procedures appear well stated, clear, conservative and rarely violated. The numbers of inadequacies were significantly reduced from the previous assessment period. Licensee policies required conservatism in entering and interpreting Technical Spect-fications. The surveillance program was effectively managed. A significant problem exists with erosion of steam pipin ~ Conclusion Rating: Category ,
f Trend: Consisten o .
22 Board Recomendation Licensee:
A baseline survey of wall thickness of pipe susceptible to erosion should be conducted on a high priority basi NRC:
Non w s- <
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E. Emergency Preparedness (211 hours, 4%) Analysis During the assessment period, there were two routine inspection One inspection was observation of the full-scale emergency pre-paredness exercise on September 10, 1985. There were no violations or reportable events noted during the assessment period which re-lated to the licensee's state of emergency preparednes Overall, the licensee has been responsive to most NRC initiatives and the findings indicate an acceptable level of performance in emergency preparednes The emergency preparedness program was being maintained at its current state. Staffing and support for the program both at the site and from the corporate office were also maintaine Actions taken towards continued improvement consisted of:
(a) Establishment of a Dose Assessment computer surveillance pro-gram to improve system availability and reliabilit (b) A Quality Assurance program verifying validity of plant meteorological dat (c) The Dose Assessment program (MIDAS) was changed to include an integrated dose calculation capability (allows totalizing sec-tor doses in 15 minute intervals to enhance offsite dose cal-culations).
 
(d) An automatic telephone ring down circuit was installed in the control room to connect all applicable emergency center (e) The onsite simulator now validates the drill scenario dat Other program improvements are in progress or being sought, however, are not yet implemente Training deficiencies, however, were noted in that not all personnel had participated in the 1985 annual training program. A repetitive finding noted that the Radiological Assessment Director (RAD) in-adequately assessed the use of potassium iodid ,
In the area of dose assessment, the post-TMI action items III.A.22 on representative meteorological monitoring and refined dose calcu-lations were still awaiting action. Coastal nuclear power plant sites need to address the complexity of wind flow patterns in the vicinity of the sit The MIDAS system (a family of computer codes for data acquisitions and dose assessment) was only used as a backup to both the manual dose calculations and verbal meteorological transfe'r of data to the EOF in the last emergency preparedness ex-
 
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ercise. The licensee has recently installed the system in the Con-trol Rooms, the TSC, and E0F to improve reliability and familiarity with the syste These concerns were discussed with the licensee during the September 10, 1985 exercise, and were highlighted by the licensee in its self-critique, which was quite thorough. The licensee's performance during this exercise demonstrated their capability to protect public health and safety within the constraints of the scenari During the period, the inspector met with local officials who indi-cated favorable working relationships with the utility. Adequate resources and routine training to county emergency preparedness personnel were provide . Conclusion Rating: Category Trend: No basi . Board Recommendaticn Licensee Non NRC None.
 
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F. Security and Safeguards (288 hours, 5.5%) Analysis During the previous SALP period, the licensee's performance in this area was Category 1. No major issues were identifie During this assessment period, three unannounced physical protection inspections were performed by regional based inspectors. Routine resident inspections continued throughout the assessment perio Interviews of security force members and observations of program implementation during inspections throughout the assessment period indicated the licensee's commitment to implement a high quality security program and to maintain an effective security organizatio This was evident by the licensee's continuing attention to program needs, prompt implementation of program enhancements, maintenance of an excellent training program, and interaction with other utili-ties regarding security matter Both plant and corporate management continue to exhibit a strong influence on the security program at Calvert Cliffs and in nuclear power industry plant security in general. This is demonstrated by the licensee's planning and budgeting for the gradual upgrading and/or replacement of security program related equipment by 198 Additio1 ally, key security management personnel are actively in-volved in the Region I Nuclear Security Association and other groups engaged in innovations in the nuclear plant security are The security staff supervisors were well trained, exhibited a pro-fessional demeanor and continued to provide effective supervision over other security force members. Other security force members were observed to perform their assigned duties in a professional, competent manner. Interviews with security force members revealed that they were encouraged to recommend improvements in the program matters they identified while carrying out their routine security dutie The training department continued to provide dedicated instructors for security training and excellent support to the security organi-zation. As part of security force training, the inspectors observed the licensee conduct very disciplined and professionally organized tactical contingency drill Security force performance during drills demonstrated the effectiveness of this training and was fur-ther demonstration of the licensee's attention to the program and its commitment to qualit .
.
 
During this assessment period, regional based inspectors advised licensee security management of generic findings as a result of Regulatory Effectiveness Reviews (RERs) conducted at other nuclear power plants. The licensee, on its own initiative, promptly imple-mented several enhancements to improve the effectiveness of its program. An RER was subsequently conducted at Calvert Cliffs during the assessment period. The results of that review indicated that the licensee's program met NRC security objectives. On matters identified during the RER which would provide easily achievable program enhancements, the licensee initiated prompt action. Other matters were promptly addressed and improvements were being consi-dered even though the licensee had not received the RER team's re-por Three security event reports were submitted in accordance with the requirements of 10 CFR 73.71. Two involved isolated cases of per-sonnel error, and the third was not specifically related to a de-crease in security system effectivenes Another event, identified by an inspector, involved an isolated error on the part of a plant employee, who was not a member of the security force. This event should have been reported under 10 CFR 73.71, but was not and a violation was cited. Yet another event, also identified by an in-
'
spector, involved equipment failure and required reporting to the NRC in accordance with the licensee's procedures and commitment These latter two events are indicative of possible confusion in the licensee's event reporting procedures. All security events were properly responded to and appropriate compensatory security measures were implemente In summary, the Security Department was a well organized, profes-sional and compentent group with excellent management suppor . Conclusion Rating: Category 1.
 
'
Trend: Consisten . Board Recommendation Licensee:
Non NRC Non . . . - -
 
- . - . _- . - - - - - _ __ .__ . .- ._ .
. .
 
  . Refueling, Outage Management and Engineering Support (841 hours, 16%)
' Analysis The previous SALP identified staff training weaknesses in ASME code requirements regarding appropriate NDE testing requirements for electrical penetrations. An additional problem was noted in this
;  area during this assessment period in that NDE equipment calibration i
procedures and recording criteria were found not to agree with ASME Section XI requirements. This indicated a need for additional training for. personnel responsible for the review and approval of NDE procedures. Training was conducted. Because additional elec-trical penetration work of this nature has not been conducted, the effectiveness of the training has not been assessed.
 
'
Two refueling outages were conducted during the evaluation period i  (Spring 1985 for Unit 1 and Fall 1985 for Unit 2). Additionally, there were several unscheduled outages on both units. Outage acti-vities observed by resident and regional inspectors included: outage coordination meetings, steam generator tube eddy current testing, replacement of salt water system heat exchanger channel heads, in-stallation of reactor vessel level monitoring system, fuel loading, new fuel inspection, containment local and integrated leak rate testing, main steam isolation and safety valve maintenance, QC in-l  spection activities, installation of reactor cavity seal and steam a
generator nozzle dams, outage radiological protection, In Service Inspections, and core loading verificatio Refueling outages were well planned and controlled. A strong effort was made to receive engineering design change packages on site at an earlier point to avoid last minute perturbations in outage re-sources and schedules. There was strict adherence to the schedule '
of activities, and good communication between licensee and contrac-tor work groups. Daily outage meetings were attended by both cor-z  porate and site management. Those meetings were succinct and ef-fective. The major portion of the fall outage was completed on or ahead of schedul The good practice of utilizing senior licensed operators to coor-dinate operations and maintenance activities was continued and fur-ther developed. This is now a permanent staff function (utilizing a shift supervisor) with an additional individual assigned during refueling outages. The recent reorganization centralized the outage coordination, operations-maintenance coordination, and the tagging functions into a single group within the operations departmen Improvements were made in the scheduling / control of post maintenance
. testing.
 
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The company reorganization late in the assessment period brought about major changes to the engineering area. Formerly, engineering functions were carried out by three major departments. Some func-tions were conducted out of the corporate office in Baltimor These functions were consolidated into one department and will all be conducted at the plant site. This is expected to reduce coordi-nation problems and minimize duplicate efforts. The licensee showed good planning in developing a transition program which anticipated losses of personnel due to job relocation and company reorganizatio A good initiative was the licensee adoption of the systems engineer concep Within the engineering area, another good licensee initiative was the additional emphasis being placed on improvements in design checklists and documentation of facility changes (this effort was in part due to the identification of documentation deficiencies noted by a NRC Equipment Qualification inspection team) and in-creased involvement of design engineers in system walkdowns (as a way of reducing the number field engineering changes required).
 
To enhance shift staffing, an initial group of four engineers were undergoing a full time, 18 month training program leading to a senior operator license and Shift Technical Advisor (STA) qualifi-cation. Upon program completion those engineers will join the operations group on shift as STA' During the 1985 refueling outages, marked human factor. improvements were made to control room panels. These included upgr<a.d indica-tor / switch labeling, board mimic diagrams, demarkation of related instrument clusters, color coding, permanent information postings, and information on instrument response characteristics to losses of power. Additionally, the control boards were cleaned and painte As stated in the Chemistry and Radiological Functional Area, signi-ficant deficiencies were identified in the PASS system. In addition to the problems noted in that area, the licensee did not subject the implementation of PASS modifications to thorough or technically sound review or test procedures. This was indicative of a program-matic breakdown in the licensee's program for verifying and vali-dating system performanc Further, in line analytical instruments and certain valves necessary to establish sample flow were inoper-able. The dominant causal factor was a lack of strong overall managerial control to assure that sufficient priority and resources were provided for identification and correction of system problem A follow up inspection indicated that the deficiencies associated with PASS were an isolated case. That is, similar deficiencies did not exist with other NUREG-0737 modification __ -- .. ._ _
    . -- .
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PASS is discussed in this section of the assessment because:
(1) of the insufficient system testing noted above; (2) an under-standing of what system constituted the " alternate" sampling method was not :learly communicated from the engineering organization to the plant; (3) the system was declared operable without procedures and training and (4) because it was representative of a problem the company recognized and was attempting to solve in the future through their development of the systems engineer concept. That is, the burden of solving this complicated system problem was placed on operating / maintenance line supervisors who are charged with many other responsibilities and who lacked sufficient technical suppor Two Equipment Qualification Inspections were conducted during the period. The NRC inspection team conducting the second inspection concluded that there was an apparent lack of management attention in the establishment of a viable EQ program. This was evidenced by the failure to take adequate corrective action for a deficiency identified during the previous EQ inspection (qualification of Rockbestos Coaxial Cable not established) and by the large number of potential enforcement / unresolved /open items identified during the follow up inspectio Apparent weaknesses were noted in engineering support for the In-strument and Controls area. Specific indicators included: (1) a design error made in a modification to the Engineered Safety Fea-tures Logic Cabinets, (2) difficulty experienced by the licensee in designing a means for conducting in-cubicle testing of reactor trip breakers, and (3) long standing problems with Unit 2 main feedwater control circuitr . Summary In summary, routine outage activities were well planned and co-ordinated. A strong management influence was involved in decision making where significant repercussion may result. Good communica-tion and orchestration of activities was demonstrated resulting in meeting schedules while minimizing rework and man-rem exposure.
 
!
Numerous upgrades of the plants were successfully made without com-plicatio However, two areas, Post-Accident Sampling System and
, Environmental Qualification of Equipment lacked sufficient manage-
!
ment attentio Changes due to reorganization and development of the system engineer concept, as well as other recent program developments, prevented recurrence of problems where multi-disciplines required coordination of management support.
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i  NRC involvement was necessary to identify deficiencies in the PASS i  and the Equipment Qualification program. The licensee should have recognized these problems through their own initiativ * Conclusion Rating: Category Trend: No basi . Board Recommendation
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Licensee:
'
Non NRC:
Schedule a meeting with the licensee to discuss licensee plans for better integration of engineering support into modification and  I outage activities.
 
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H. Licensing Activities Analysis During the SALP evaluation period, the licensee continued to show good management overview in the area of licensing activities. The majority of the licensing actions completed during the SALP period were resolved within the licensing group at Calvert Cliffs (or via technical experts utilized by the licensing group). In the few in-stances where matters were referred to the licensee's upper manage-ment, these individuals proved to be well informed and helpful in resolving questions of a corporate nature. For example, the licen-see's Vice President for Supply was directly involved in the reso-lution of the Radiological Effluent Technical Specifications (RETS)
,
d and problems associated with Post-Accident Sampling. The licensee's management also showed itself to be innovative and forward thinkin During the SALP period, the license (1) obtained a full 40 year operating license for Calvert Cliffs, Units 1 and 2; (2) worked diligently to establish an industry position on station blackout; and (3) requested a reduction in their emergency planning zone from 10 miles to 2 mile A summary of licensing activities is contained in Table 7. The licensee's submittals were usually timely and of high quality. Of particular note was the licensee's treatment of the "significant hazards consideration" standards of 10 CFR 50.92, " Issuance of Amendments." During the SALP period, the licensee substantially improved the way in which "significant hazards considerations" were addressed and now presents detailed safety analysis and plant-speci-fic design information in addressing the standards of 10 CFR 50.9 The licensee continued to maintain a significant technical capabil-ity in almost all engineering and scientific disciplines necessary to resolve items of concern to the NRC and the licensee. The lic-ensee continued to utilize the services of Combustion Engineering for accident analysis. However, the licensee was improving its accident analytic capability and had submitted a request for review and approval of the RETRAN model for Calvert Cliff The NRC also benefited from the licensee's technical capabilities as a result of NRC's request for comments and/or participation in the following:
  --
Seismic Qualifications of Equipment (USI A-46)
  --
Safety Implications of Control Systems (USI A-47)
  --
Pressurized Thermal Shock (USI A-49)
The licensee continued to respond promptly to all NRC staff initi-atives. During the SALP period, the licensee assisted the NRC in resolving a number of multi plant (generic) items and TMI Action
 
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item In each case, the licensee carefully evaluated the item in question to assure the degree of applicability to Calvert Cliff Where requirements were generic rather than plant-specific, the licensee diligently negotiated changes in requirements to assure that the final requirements (e.g., Technical Specifications or equipment design) fully reflect the Calvert Cliffs plant desig In some cases, the licensee's upper management was involved in final negotiations. In all cases where the licensee's position did not meet the final NRC position, the licensee changed their position to achieve conformanc During the SALP period, one enforcement action was directly related to licensing activities. The subject enforcement resulting from the inadequacy of the post accident sampling system (PASS). This action was significant from a licensing standpoint in that the TS was proposed for an unproven system and the licensee should not have proposed the TS until the PASS had been shown to be reliabl Sec-tion G, " Refueling, Outage Management, and Engineering Support,"
presents additional details on this issu In summary, the licensee's licensing activities were conducted by a well staffed and well trained group resulting in an overall effi-cient operation. Management overview was obvious in that the lic-ensing group was, for the most part, well integrated into other plant activities and licensing activities reflected a uniform ap-proac Upper management became directly involved in licensing ac-tions only rarely to assist in resolving potential deadlocks. The licensee is to be commended for the diligent way in which multi-plant (generic) and TMI Action Items were resolved and the willing-ness of the licensee to compromise when necessary to achieve agree-ment with NRC position . Conclusion Rating: Category Trend: Consisten . Board Recommendation Licensee:
Non NRC:
None.
 
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I. Assurance of Quality Analysis During this assessment period, management involvement and control in assuring quality is being considered as a separate functional area for the first time and continues to be one evaluation criterion for each functional area. The various aspects of Quality Assurance Program requirements have been considered and discussed as a integ-ral part of each functional area and the respective inspection hours are included in each one. Consequently, this discussion is a synop-sis of the assessments relating to quality work conducted in other areas. However, it is not solely an assessment of the QA/QC de-partment The licensee has dedicated significant resources and emphasis to the assured quality of their work, and emphasizes that quality is a line function. Increased emphasis was placed on assessing effec-tiveness of plant programs. For example, early in the SALP period, licensee management effectively used QA personnel to perform an in depth auditing effort to identify administrative and technical de-ficiencies in surveillance test procedures (STP's). The Quality Control staff was extensively involved in monitoring corrective maintenance, surveillance testing, and modification activitie The effectiveness of the licensee's QA organization was shown by the identification of improper vendor substitutions of non-safety grade air filters for safety grade filter QC coverage of both primary and secondary maintenance and surveil-lance activities was noted to be extensiv Routine audits performed by the QA staff were well planned and thorough, and audit findings were resolved within a reasonable time frame. However, audit findings have routinely appeared to be minor in nature with little impact on the specific progra Audits were only of tradational areas / departments and generally did not assess nor "second guess" management /POSRC decisions. Audits were often quite superficial and presented additional paperwork and a burden
,  to various departments with several " nits" rather than identifying
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real problems, attempting to identify the root cause(s), and pro-viding appropriate recommendation Management and the onsite review and offsite review committees were not effective in their reviews to assure quality in the acceptance of the Post Accident Sampling System considering the many problems
;
associated with it, and in the inadequate maintenance of the En-vironmental Qualification of components. The Plant Operation and Safety Review Committee was often less than effective in implement-
,
ing their role as a safety committee to ensure understanding of root
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causes of several plant trips (see Maintenance functional area).
 
Considerable NRC attention was required prior to the licensee in-itiating adequate action regarding several potential safety issues (see Operations functional area). Quality in the initial decisions for corrective action was not effective in preventing recurrence of loss of shutdown cooling, feed pump / reactor trips, feedwater heater level / reactor trips, and repetitive shutdowns due to main steam isolation valve problems (see Table 6).
 
Independent of the above, as a result of a licensee reorganization, major changes were made (late in the period) which are indicative of effort to improve the quality effectiveness as follows:
(1) To provide greater depth of insight, a pilot program was im-plemented using senior licensed individuals (of the operations department and currently assigned to shifts) to conduct QC surveillances of operational activities. A similar program was implemented in the chemistry are (2) QC personnel were transferred from the QA department to line departments (however, they remained as separate groups within those departments to preserve independence). This was done to provida more effective (less adversarial) working relation-ships between QC and line personnel. The licensee wanted to provide the line departments with an improved tool to ensure work was being accomplished correctly under the philosophy that quality is a line functio Enhanced cross training programs for QC and line groups was initiate (3) QC controls are now being provided for selected non-safety related maintenance activitie (4) Efforts were made to improve audit effectiveness by increased QA supervisor participation in audit planning and review and by making audits more technical in natur (5) Audits similar in nature to recent NRC IDI and PAT team in-spections are planned.
 
l (6) Material receipt inspections will be expanded to include in-i creased dimensional checks of parts.
 
'
(7) The QA staff was strengthened by the addition of a General Supervisor with previous experience as the General Supervisor of Operations. Additionally, a senior licensed engineer was added to the staff.
 
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  - _ _
 
.
.
 
(8) The practice of conducting audits of areas of special concern to licensee management was continued (e.g. compliance of NUREG 0737 requirements, Reactor Coolant Pump overhaul activities).
 
In summary,'although an extensive quality program existed throughout the organization, the. visible contribution incorporating quality in the important safety issues appears lacking. Quality effective-ness was also limited in the line functions, specifically in the I&C area, resulting in numerous plant trips. New initiatives were implemented in this area late in the assessment perio . Conclusion Rating: Category Trend: No basi . Board Recommendation:
Licensee Non NRC Non . _ _ -
 
.
.
 
J. Training and Qualification Effectiveness Analysis Although attributes of this topic are discussed in each SALP func-tional area, the topic here is segregated because of its importance, and to provide a synopsis of the effectiveness of the training and qualification programs. Training effectiveness was measured pri-marily by the observed performance of licensee personnel and, to a lesser degree, by reviews of program adequac The discussion below addresses three principle areas: licensed operator training, non-licensed staff training, and the status of INPO training accre-ditatio INP0 accreditation for the site was scheduled for completion by the end of June 1986. Three operator training programs and health physics and chemistry were approved by the end of the assessment period. Instrument and Controls, maintenance electricians and the STA programs v re submitted in January 1986. The final two programs for mechanica' anaintenance and the technical staff were due to INP0 by June 30, 198 Effectiveness of training for most departments was good as evidenced by few personnel errors, a low man rem dose rate and timely assess-ment and response to abnormal occurences by plant operators. Train-ing in the Maintenance Mechanical area was less than effectiv A lack of engineering support to provide torque specifications re-sulted in over torquing pressurizer spray valve fasteners. Many components may remain over torqued because of the duration of the maintenance program without appropriate training in this are Maintenance training was also noted to be lacking with respect to rebuilding Reactor Coolant Pump Seals when the resident inspector observed a component being installed backward Other areas where training was provided but appeared less than ef-fective was within the Instrument and Controls Department. Training appeared comprehensive and attendance was good. Facilities and support appeared appropriate. However, several personnel errors were noted where technicians failed to follow procedures causing a loss of shut down cooling, recirculation actuation signals, and other Emergency Safety Feature actuation Additionally, several plant trips occurred due to grounds on control systems or undeter-mined causes associated with control mechanisms which instrument and controls troubleshoots often unsuccessfull Reviews of training for non-licensed staff indicated that great strides were being accomplished in an area where signiiicant weak-nesses were noted in licensee's prior performance related to main-
'
.- tenance technical training. The licensee recognized the maintenance
,
department's previously weak training program and, as part of the e
 
  -- . - - - . - - . . _ . - - _ - -- --. .. _- - - - - ..
.
37 i  site effort to become INPO accredited, included considerable spe-cialized training improvements for reactor coolant pump seal re-placement, rebuilding safety valves, control valves and actuators, i  fasteners and coupling and machinery alignmen (Problems in these
!
areas in the past led to unit shut downs or aggravated operations.)
:  A machinery mechanic training and qualification program was devel-
!  - oped bringing a formalized qualification program for levels 1, 2, and 3 mechanics. This ensured a formal base line knowledge in basic math, plant systems, print reading, first aid and radiological safeguards type material for all personnel. Equipment maintenance qualifications, with courses provided for each type of valve, pump, i
compressor, and actuator within the plant up to level 3 training i  on reactor assembly / disassembly, governors, diesel generator equip-
!  ment and electrohydraulic controls were also provided. Schedules provide for classroom, laboratory, on the job, and recurring train-ing. These qualification programs were or were being developed for each area within the maintenance department, health physics and operations.
 
;  In addition to the recent task analysis, procedure development and
-
qualification program, the licensee dedicated significant hardware resources to training beginning with the site specific simulator primarily for licensed operators. Both the maintenance electricians and instrument and control had training laboratories with state of
,
the art training aids provided. Functional laboratories were pro-
 
vided for health physics and chemistry and maintenance. Mockups
,  were provided for steam generator primary side man ways, reactor coolant pump seal and various valve ,
Although the licensee recognized and implemented corrective action .
for the previously marginal training in the maintenance area, and
,  supplemented the training programs of other areas with INPO accre-ditation, the effects of the accreditation were yet to be seen.
 
,
Discussions with licensed operators reflected little knowledge of probablistic risk assessmen Operators were not cognizant of i  systems / components that are significant risk contributors or what l  possible effects working on these systems / components might have.
 
!
l  In summary, training programs were in place and were being upgraded I  with INPO accreditation nearly complete. Appropriate resources and
!  management attention were dedicated. Significant improvements were made in the previously weak maintenance program, however effective-ness of improvements was yet to be seen, f
i T
.- - - . .~ . . _ .
 
- . . _ . . _ . _ - . - _ . . _ - . . . . .
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SEP 2 51986 Docket Nos. 50-317; 50-318 Baltimore Gas and Electric Company ATTN: Mr. J. A. Tiernan Vice President Nuclear Energy P. O. Box 1475 Baltimore, Maryland 21203 Gentlemen:
!        38
Subject: Management Meeting This is to confirm arrangements for a management meeting scheduled for 10:00 a.m.,
!
October 8, 1986 at the Region I Office, King of Prussia, Pennsylvania. The purpose of this meeting is to-provide you the opportunity to present information relative to the forthcoming outage pursuant to the recommendations of SALP Report 50-317/
.
84-99; 50-318/84-99. Time will be made for other matters which you may wish to presen Please forward a meeting agenda to this office, to the attention of Mr. L. E. Tripp, Chief, Reactor Projects Section 3A, by close of business on October 3, 198 Your cooperation in this matter is appreciate
1 Conclusion
              .
              '
;    Rating: Category ;
Trend: Consisten , Board Recomendation N
!  Licensee          !
,
!  Non !
,
NRC
 
I None.


i f
Sincerely,
i i
!


5 i
MiMIFi Rane, Director Division of Reactor Projects cc:
              *
M. Bowman, General Supervisor, Technical Services Engineering Thomas Magette, Administrator, Nuclear Evaluations Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
'NRC Resident Inspector State of Maryland (2)
i
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_ _ _ .
., .s
  .
  .
39 V. SUPPORTING DATA AND SUMMARIES Investigations and Allegations Review During this assessment period three allegations were received. Two al-leged adverse background information for (2) contractor employees. This information was provided to the licensee for further investigation. In-formation gained from follow on investigation led to the removal of site access for one of the individuals. In the second case, the licensee determined no action was necessar The third allegation, regarding an improper entry into high radiation areas, was received near the end of the SALP period and was still under revie Inspector effort was continued on five allegations made by a single wor-ker at the end of the previous SALP period, which stated that improper administrative control actions caused the worker to receive a radiation exposure in excess of regulatory limits. The allegations were partially substantiated and two violations were issue An investigation was conducted by the Office of Investigations regarding improper vendor substitution of commercial grade HEPA filters for safe grade filter Escalated Enforcement Actions Civil Penalties One civil penalty was issued on September 26, 1985 resulting from identification of significant deficiencies in the Post Accident Sampling System (PASS). Orders Non . Confirmatory Action Letters f
Non Management Conferences Held During the A".sessment Period A management meeting (July 11, 1985) and, subsequently an enforcement conference (August 14, 1985) was held regarding deficiencies in the PASS Syste A 4 *.a _*= %a5 a-- - -J,41r42I.-a+ _.4__a- . _ -e aM _ Ma.-m-- . 14...J_a.24  .2 _ h w . _i~_a
.4._mu
,
,
.        40 i
i
, Licensee Event Reports (LERs)
,  Tabular Listing            .
-
TYPE OF EVENTS      Unit 1  Unit 2  i Personnel Error. . . . . . . . .      4 . . . . . . 3 Design / Man.Constr./ Install . . .      6 . . . . . . 2
' External Cause . . . . . . . . .      2 . . . . . . 1 Defective Procedure    . ..... 5...... 0
, Component Failure  . . ..... 3...... 5 Other . . . . . . . .    ..... 2...... 6
'
Total . 39
!
Licensee Event Reports Reviewed:
i'
Report Nos. 317/84-13 through 86-02; and 318/84-08 through 86-0 ,
i.
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  -
  -
-I
Baltimore Gas and Electric Company 2 SEP 25 W bec:
:
Region I Docket Room (with concurrences)
 
Management Assistant, DRMA (w/o encl)
,
DRP Section Chief M. McBride, RI, Pilgrim T. Kenny, SRI, Salem D. Jaffe, LPM, NRR Robert J. Bores, DRSS R P DRP RI:DRP P ipp fgb h/meo Wenzinger en8/88 9p qu 0FFICIAL RECORD COPY
 
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. _ _ _ _ _ _  __ __ . ._  __
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-
TABLE 1
;. INSPECTION REPORT ACTIVITIES
,
UNIT 1/ UNIT 2 INSPECTION REPORT NUMBERS HOURS AREAS INSPECTED
{
84-26/84-26 108 IE Bulletins 79-02, 79-04, 79-07, and 79-14
! 84-27/84/27 289 Equipment Qualification 84-28/84-28 32 Chemistry 84-30/84-30 40 Operator Examination 84-31/84-31 169 Routine Resident 84-32/84-32 44 Radiation Protection Program 85-01/85-01 214 Routine Resident 85-02/85-02 238 Routine Resident 85-03/85-03 0 Cancelled 85-04/85-04 81 Non-License Training and QA Program 85-05/85-05 28 Radiation Protection Pre-Outage 85-06/85-06 56 Environmental Protection Program and Training 85-07/85-07 220 Routine Resident-85-08/85-08 68 Physical Security 85-09/85-09 259 Routine Resident 85-10 67 Containment Leakage Testing Program 85-11 37 In Service Inspection 85-12/85-10 50 Radiation Protection 85-13/85-11 120 Routine Resident 85-14/85-12 64 Radiation Environmental Monitoring 85-15/85-13 272 Routine Resident
    - . - _ _ _
 
  .
  . . .
_ ___  _-
.
T-1-2 UNIT 1/ UNIT 2 INSPECTION REPORT NUMBERS HOURS AREAS INSPECTED 85-16/85-14 190 TAP PASS, Effluent Monitors 85-17/85-15 20 Radiation Safety 85-18/85-16 180 PASS 85-19/85-17 64 Radioactive Liquid and Gaseous Effluent Program 85-20/85-18 0 Enforcement Conference 85-21/85-19 0 Cancelled 85-22/85-20 245 Environmental Qualification 85-23/85-23 40 Operator Examinations 85-24/85-21 210 Routine Resident 85-25/85-22 190 Emergency Preparedness 85-26/85-24 41 Safeguards 85-27/85-25 56 Radiation Protection Pre-Outage 85-28/85-28 237 Routine Resident 85-29/85-30 33 Transportation 85-31 42 Refueling Activities 85-30/85-32 186 Routine Resident 85-31/85-26 31 Radiation Protection 85-32/85-27 190 Operator Requalification Program 85-33/85-33 126 Local Leak Rate Tests and Integrated Leak Rate Tests 85-34/85-34 185 Routine Resident 85-35/85-35 29 Radiation Protection 86-01/86-01 49 IE Bulletin 80-11, Masonry Wall Design 86-02/86-02 68 Dosimetry Inspection
 
  . .. . _ - -  ... - . ,_ -  - - .  - - . --_ _ _ -
.
.
j      T-1-3
'
UNIT 1/ UNIT 2  INSPECTION REPORT NUMBERS  HOURS AREAS INSPECTED 86-03/86-03  136 Routine Resident 86-04/86-04  32 Physical Security 86-07/86-07  220 Routine Resident TOTAL HOURS  5258 i
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.
.
TABLE 2 INSPECTION HOUR SUMMARY (10/1/84 - 4/30/86)
HOURS % OF TIME Plant Operations........................... 1295 24.6% Chemistry and Radiological Controls. . . . . . . . 901 17.0% Maintenance................................ 837 16.0% Surveillance............................... 885 16.8% Emergency Preparedness..................... 211 4.0% Security and Safeguards.................... 288 5.5% Refueling...................... ........... 841 16.0% Licensing Activities....................... NA NA Assurance of Quality....................... NA NA 10. Training and Qualification Effect.......... NA NA TOTALS 5258 100%
 
..
.
TABLE 3 VIOLATIONS (10/1/84 - 4/30/86)
A. Number and Severity Level of Violations Severity Level I 0 Severity Level II 0 Severity Level III 2 Severity Level IV 14 Severity Level V _4 Total Violations 20 B. Violations Vs. Functional Area Severity Levels Functional Areas  I II III IV V Plant Operations  1 4 2 Chemistry and Radiological Controls  4 1 Maintenance Surveillance    2 1 Emergency Preparedness Security and Safeguards  3 Refueling, Outage Management, and Engineering Support  1 1 Licensing Activities  _ __ _
Totals  2 14 4 Total Violations  20
 
. T-3-2 Summary Inspection Inspection  Severity Number Dates Requirements Level Area Subject 317/318 84-26/82-26 10/1-5/84  De Refuel Piping systems'identi-fled as Reactor Coolant and the pressurizer surge lines had not been. inspected and verified for agreement with corresponding seismic analysis on Calvert Cliffs Unit /84-32 11/26-30/84 TS IV Rad Failure of workers to comply with Special Work Permit 85-01/85-01 12/18/84- TS 6.12 IV Rad Failure to Post High 1/22/85  Radiation Area in Five Foot West Penetration Are /85-09 4/1-5/6 TS 3/4 9.3. V Ops Source Range Nuclear Flux Monitor was not Audible in the Control Roo /85-11 5/6-6/17 TS 6.8.la IV Ops Two instances of per-Surv sonnel failure to fol-low procedures resulted in: U1 Shutdown Cooling Flow Loss when RCS Pressure Increased Above 284 PSIA; Two of Four U2 RWT Level Switch Channels were Tripped at one time during STP M-220- ..
 
    - _ . _ __
e T-3-3 Inspection Inspection  Severity Number Dates Requirements Level Area Subject 85-16/85-14 6/24-6/28 NRC Order III Refuel Significant deficien-TS 3.7.13 III Ops cies associated with 85-18/85-16 7/16-7/26 NRC Order IV Refuel PASS, e.g. inadequate TS 4. IV Surv testing, design, train-TS 6.15 IV Ops procedure Inadequate protective sleeving (EQ) for in-containment hi range radiation monitors. Missed sur-veillance testing on main vent iodine and particulate sampler.
 
'
85-17/85-15 7/1-3/85 10 CFR 20.201 IV Rad Worker received radi-ation dose higher than allowed for condition where NRC Form 4 not completed.
 
10 CFR 20.201 IV Rad Improper reporting of above even /86-03 1/20-3/3 TS 3.6. IV Ops U1 1-SV-6529 Discovered
!
to be Open Without Administrative Contro (Containment Isolation Valve).
 
,
'
86-04/86-04 2/18-21/86 Sec. Plan IV Se Failure to check an alar Sec. Plan IV Se Failure to report.
 
i 86-05/86-05 3/3-7/86 TS 6. V Rad Procedure for stand up whole body counter not properly approve TS 4.6. IV Surv Inadequacy in lab analysis program for charcoal absorber materia .
 
_ - .    - .- . .  . . _
d T-3-4 Inspection Inspection  Severity
) Number  Dates Requirements Level Area Subject 86-07/86-07 3/4-4/30 10 CFR 50 V Surv Unit 1 High Pressure Safety Injection Pump Discharge Pressure gauge inadequate for
'
use, (out of calibra-tion) to demonstrate functional acceptance
:      of safety systems.
 
'
10 CFR 50 V Ops Installed instrument not tagged or labelled indicating date of
        '
.
'
calibration or identify of person performing calibratio CFR 50 IV Ops Post maintenance test App 8  accomplished by pro-cedures not appropriate to the circumstances 4      resulting in inadvert-ent isolation of Unit 2 shut down cooling system. Ineffective corrective actions
,      following earlier events led to recurring losses of shut down coolin Sec. Plan V Sec Security violation.
 
,
A
      . _ _ . . _ .
_ . - . . -- - -_ _- . .
    , _ _ . __ . .
 
_ - - . -.
    . . . . _ _ _-. .____ _ _ -_ _ .. .<    ,
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  .
 
h TABLE 4 TABULAR LISTING:0F LERS BY FUNCTIONAL AREA AREA    -
NUMBER /CAUSE CODES Plant Operations    4/A 0/8 3/C 0/D 0/E 0/X Chemistry and Radiological Controls  0/A 0/8 0/C 0/D 0/E 0/X Maintenance  - _
1/A 4/B 0/C 3/D 7/E 3/X Surveillance    2/A 4/B 0/C 2/D 1/E 5/X Emergency Preparedness    0/A 0/8 0/C 0/D 0/E 0/X
' Security and Safeguards    0/A 0/B 0/C 0/D 0/E 0/X s Refueling, Outage Management and Engineer Support 0/A 0/8 0/C 0/D 0/E 0/X
    , Licensing Activities  '
0/A 0/B 0/C 0/C 0/E 0/X
  ,
Cause Codes      U1 U2 Total Personnel Error    4 3 7 Design / Man./Const. Instal External Cause    2 1 3 Defective Procedure    5 0 5
    ': Management / Quality Assurance Deficiency  3 5 8 Other      2 6 8
 
Totals 22 17 39
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TABLE 5 ,
    *
LER SYN 0PSIS LER NUMBER SUMMARY DESCRIPTION UNIT 1 84-13 Loss of Circulating Water Caused by Sea Nettle Impingement 84-14 Battery Inoperable 84-15 Loss of Circulating Water Caused by Sea Nettle Impingement 84-16 HPSI Injection Leg's Flow Imbalanced 84-18 #11 MSIV Inoperable
    )
84-19 Failure of #12 MSIV to Fully Close during Surveillance 85-01 Excessive Safety Injection Tank Check Valve In Leakage 85-02 Reactor Trip on Low Steam Generator Water Level Condition Resulting from a Temporary Loss of Main Feed Water 85-03 MSIV Setpoints Out of Tolerance 85-04 ESFAS Occurred During Surveillance Testing with Unit in Mode 4 85-05 Inadvertent Initiation of Steam Generator Isolation 85-06 UGS Removal Without Fuel Handling Supervisor Present 85-07 HPSI Injection Leg's Flow Imbalanced 85-08 Reactor Trip Caused by Moisture Separator High Level 85-09 Reactor Trip on Low Steam Generator Water Level 85-10 Reactor Trip caused by Improperly Set Main Turbine Thrust Bearing Wear Detector  s 85-11 MainTurbineTripDuetoanUndetermhnedCause 85-12 Main Turbine Trip Due to a Grounded Feed Water Heater Level Control Switch 85-13 RCP Shaft Seal Bleed Off Line Weld Failure 85-14 Control Room Ventilation Damper Failure
    /
 
^
-  '
 
  ,a
 
T-5-2 LER NUMBER SUMMARY DESCRIPTION 86-01 Reactor Trip Caused by Failure of TCB #2 During Surveillance Testing 86-02 Inadvertent Closing of Shutdown Cooling Return Valve Unit 2 84-08 Reactor Trip Due to Loss of #22 Main Feed Water Pum Cause Unidentifie Manual Trip Caused by Degradation of #21A Reactor Coolant Pump
,
Shaft Seal 85-02 Reactor Trip Caused by an Inadvertent Actuation of #21A RCP Over Current Device 85-03 Incorrect Fastener Material used in Pressurizer Spray 85-04 Control Room Post LOCI Filter System Inoperable 85-05 Recirculation Actuation Signal Inadvertent Initiation 85-06 Inoperable Diesel Generators 85-07 Failure to Perform Required Surveillance on Noble Gas Monitor 85-08 Failure of #21 MSIV to Fully Close during Surveillance Testing 85-09 Blockage of Saltwate Flow to Service Water Heat Exchanger #21 85-10 Pressurizer Safety Valve Setpoint Out of Specification 85-11 Main Steam Safety Valve Set Points Out of Specification 85-12 Reactor Trip on Low Steam Generator Water Level 85-13 Inadvertent Initiation of Engineered Safety Features During Mode
 
86-01 Violation of TS for Pressurizer Over Pressure Protection during Cold Shutdown Conditions 86-02 Inadvertent Trip of Main Turbine from Engineering Safety Features Actuation System  ,
86-03 Inadvertent Engineered Safety Features Actuation Due to Failed Logic Module
 
.
O TABLE 6 UNPLANNED AUTOMATIC TRIPS AND FORCED OUTAGES DATE AND UNIT POWER LEVEL DESCRIPTION  CAUSE 1 10/2/84 Manual trip following accumulation of jelly Desig % fish o,n intake structure screens, to avoid damage to screens and circulating water pumps and low condenser vacuum conditio /3/84 Unit tripped on low steam generator water FW control prob-92% level due to loss of #22 main feed water problems (possibly pum The exact cause of pump trip could due to grounds).
 
not be determined but was believed to origi-nate in the automatic speed control circuitr /20/84 Manual trip following accumulation of jelly Design 100% fish on circulating water screens, to avoid damage to screens and circulating water pumps and low condenser vacuum condition /12/84 Controlled shutdown due to a concern that Equipment prob-100% #11 Main Steam Isolation Valve might be i lem (possible inoperabl design / maintenance related).
 
1 01/16/85 Controlled shutdown to repair Safety Injec- Possible main-100% tion Tank check valve leakag tenance deficienc /01/85 Reactor trip on low steam generator water Miscommunication 100% level following loss of both main feed water between operator pumps (MFWP). MFWP trips were caused by and control roo operator error in mistakenly opening a con-trol power breake /25/85 Precautionary manual trip by operator due to Precautionary 100% failed Reactor Coolant Pump sea tri /05/85 Reactor trip on low reactor coolant flow due Random failur % to loss of Reactor Coolant Pump #21 /17/85 Precautionary shutdown to inspect and re- Precautionary (to 100% place pressurizer spray valve fastener correct mainten-ance problem).
 
2 07/18/85 Controlled shutdown to repair two pin hole Weak B0P surveil-100% size steam leaks on a cold turbine reheat lanc lin .
 
.
      }
,
T-6-2 DATE AND UNIT POWER LEVEL DESCRIPTION  CAUSE 1 08/06/85 Reactor trip due to turbine trip as a result Personnel erro % of high level in Moisture Separator Reheater (mispositioned isolation valve).
 
1 08/06/85 Trip due to low steam generator water level Personnel erro % due to operator difficulties in manually maintaining steam generator level with posi-tive moderator temperature coefficien /07/85 Reactor trip caused by turbine trip due to Maintenance or 50% improper alignment of thrust bearing wear desig detecto /30/85 Reactor trip caused by turbine trip due to Maintenanc % ground in feed water heater level circui /02/85 Reactor trip caused by turbine trip due to Continuing main-100% continuing ground in feed water heater level tenance proble circui /09/85 Controlled shutdown due to cracked weld on Design or bad 100% Reactor Coolant Pump bleed off lin wel /12/85 Trip on low steam generator water level due FW control prob-46% to loss of #21 Main Feed Water Pump due to lems (possibly faulty control circuitry,  due to grounds).
 
1 01/13/86 Reactor trip due to malfunction of a Reactor Manufacturing 100% Trip Breaker during surveillance testin erro /04/86 Reactor trip caused by turbine tri Apparent spurious 100%    SG high level signal.
 
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TABLE 7 SUMMARY OF LICENSING ACTIVITIES 1. NRR LICENSEE MEETINGS March 27, 1986 Reactor Coolant System High Point Vent Technical Speci-fications December 13, 1985 Main Steam Line Safety Valves - Setpoint Problems September 7, 1985 Control of Heavy Loads August 26, 1985 Post-Accident Sampling System July 10, 1985 Containment Purge and Vent. Valves April 24, 1985 Masonry Wall Evaluation March 20, 1985 Reactor Coolant Pump Seal Cooling 2. NRR SITE VISITS March 20, 1986 Security Retraining and Inspect Plant Housekeeping January 27-31,1986 Inspection of Boric Acid Subsystem December 5, 1985 Inspect Plant Housekeeping Sept. 23-26, 1985 Inspect Spent Fuel Pool Cooling System August 26, 1985 Control Room Habitability Inspection July 19, 1985 Post-Accident Sampling System Inspections (exit interview)
June 24, 1985 Security Retraining and Inspect Plant Housekeeping April 4, 1985 Inadequate Core Cooling Instrumentation Inspection February 8, 1985 Inspect Plant Housekeeping January 16, 1985 Inspect MSIVs and Obtain Data on Recent Failures 3. COMMISSION BRIEFINGS Non J
 
c-
,
. J T-7-2 4. SCHEDULAR EXTENSIONS GRANTED March 31, 1985 Environmental Qualifications Schedule Extension 5. RELIEFS GRANTED April 18, 1985 ASME Code - Common start for Calvert Cliffs Units 1 and 2 Programs May 20, 1985 ASME Code - Pressurizer Spray Line Inspection September 18, 1985 ASME Code - Reactor Coolant Pump Weld Inspection November 14, 1985 ASME Code - System Pressure Tests March 10, 1986 ASME Code - Pump Tests 6. EXEMPTIONS GRANTED January 8, 1986 Appendix J to 10 CFR Part 50 - ISI/ILRT Schedule 7. LICENSEE AMENDMENTS ISSUED April 14, 1986 License Amendments 117 and 99 - Miscellaneous TS Changes (applications dated February 22, 1985 and October 25, 1985)
March 31, 1986 License Amendment 116 (Unit 1) - Incore Detector TS February 20, 1986 License Amendments 115 and 98 - Containment Vent TS February 19, 1986 License Anendments 113 and 96 - Post Accident Sampling System TS January 8, 1986 License Amendments 112 and 95 - ILRT/ISI Schedule December 31, 1985 License Amendments 111 and 94 - Diesel Generator TS December 30, 1985 License Amendments 110 and 93 - Organizational Charts
.
December 9, 1985 License Amendments 109 and 92 - Miscellaneous TS Changes l
.
  (application dated April 26, 1985)
 
; December 4, 1985 License Amendments 108 and 91 - Miscellaneous TS Changes (application dated June 28, 2985)
November 21, 1985 License Amendment 90 - (Unit 2) Cycle 7 Reload
!
August 30, 1985 License Amendment 89 - (Unit 2) TS Changes in Support of cycle 7 Reload
!
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O T-7-3 August 26, 1985 License Amendments 107 and 88 - TS for TCS Leakage August 1, 1985 License Amendments 106 and 87 - Alternate STA Qualifica-tio July 1, 1985 License Amendments 105 and 86 - RETS (Effluent Monitoring)
May 20, 1985 License Amendment 104 - (Unit 1) Cycle 8 Reload May 16, 1985 License Amendments 103 and 85 - Miscellaneous TS Changes (applications dated September 20, 1984 and January 31, 1985)
May 1, 1985 License Amendments 102 and 84 - License Expiration Dates March 7, 1985 License Amendments 101 and 83 - Revised TS for Halon Systems February 22, 1985 License Amendments 99 and 81 - GL 83-37 (TS for TMI Action Items)
February 14, 1985 License Amendments 98 and 80 - ILRT Schedule January 14, 1985 License Amendments 97 and 79 - Miscellaneous TS Changes (applications dated April 9, 1984 and June 29, 1984)
8. EMERGENCY TECHNICAL SPECIFICATIONS ISSUED Non . ORDERS ISSUED July 16, 1985 Order Modifying License Confirming Additional Licensee Commit-ments on Emergency Response Capability (Supplement 1 to NUREG-0737)
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Latest revision as of 01:33, 3 December 2021

Confirms Scheduled Mgt Meeting on 861008 at Region I Ofc Re Util Presentation Concerning Forthcoming Outage Per Recommendation of SALP Repts 50-317/84-99 & 50-318/84-99. Meeting Agenda Requested by 861003
ML20210S304
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 09/25/1986
From: Kane W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Tiernan J
BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 8610080081
Download: ML20210S304 (2)
v • d • e


Text

v i

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SEP 2 51986 Docket Nos. 50-317; 50-318 Baltimore Gas and Electric Company ATTN: Mr. J. A. Tiernan Vice President Nuclear Energy P. O. Box 1475 Baltimore, Maryland 21203 Gentlemen:

Subject: Management Meeting This is to confirm arrangements for a management meeting scheduled for 10:00 a.m.,

October 8, 1986 at the Region I Office, King of Prussia, Pennsylvania. The purpose of this meeting is to-provide you the opportunity to present information relative to the forthcoming outage pursuant to the recommendations of SALP Report 50-317/

84-99; 50-318/84-99. Time will be made for other matters which you may wish to presen Please forward a meeting agenda to this office, to the attention of Mr. L. E. Tripp, Chief, Reactor Projects Section 3A, by close of business on October 3, 198 Your cooperation in this matter is appreciate

Sincerely,

MiMIFi Rane, Director Division of Reactor Projects cc:

M. Bowman, General Supervisor, Technical Services Engineering Thomas Magette, Administrator, Nuclear Evaluations Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

'NRC Resident Inspector State of Maryland (2)

i

, ,

L

- . , _ - - - - -

_ _ _ .

., .s

.

-

Baltimore Gas and Electric Company 2 SEP 25 W bec:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

DRP Section Chief M. McBride, RI, Pilgrim T. Kenny, SRI, Salem D. Jaffe, LPM, NRR Robert J. Bores, DRSS R P DRP RI:DRP P ipp fgb h/meo Wenzinger en8/88 9p qu 0FFICIAL RECORD COPY

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