IR 05000317/1985034

Insp Repts 50-317/85-34 & 50-318/85-34 on 851211-860120.No Violation Noted.Major Areas Inspected:Control Room, Accessible Parts of Plant Structures,Plant Operations, Radiation Protection & Physical Security

ML20151Y757
Person / Time
Site:	Calvert Cliffs
Issue date:	02/04/1986
From:	Elasser T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151Y748	List: IR 05000317/1985034 ML20151Y746
References
50-317-85-34, 50-318-85-34, GL-83-28, IEB-85-003, IEB-85-3, NUDOCS 8602130127
Download: ML20151Y757 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

. Region I Docket / Report: 50-317/85-34;-50-318/85-34 License: DPR-53; DPR-69 Licensee: Baltimore Gas and Electric Company Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2

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Inspection At: Lusby, Maryland Dates: December 11, 1985 - January 20, 1986 Inspectors: T. Foley, Senior Resident Inspector D. C. Trimble, Resident. Inspector ,

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I C. Elsasser, Chief, Reactor Projects Section 3C Date Summary: December 11 - January 20, 1986: Inspection Report 50-317/85-34;

50-318/85-34 ,

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Areas Inspected: Routine resident inspection of the Control; Room, accessible. parts of plant structures, plant operations, radiation protection, physical security, fire protection, plant operating records, maintenance, surveillance, open items, and reports to the NR Inspection hours totalled 157 hour0.00182 days <br />0.0436 hours <br />2.595899e-4 weeks <br />5.97385e-5 months <br /> Results: Licensee transition through a major reorganization was monitored closely.

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One goal of the reorganization is to focus more management attention on nuclear

operations. This_in combination with other objectives has the potential for pro-

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ducing significant improvements in plant operation. Some confus, ion, however, was noted in individuals.at several levels of the organization (ranging fr.om technician to middle management) regarding the organization and personnel staffing of depart-ments other than their own (Section 10).

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Improvements were noted in the area of post maintenance testing. Increased emphasis is being placed by the licensee on this area and on operations / maintenance coordina-tion in general. One problem was identified in that one post maintenance test (re-verse flow) on certain safety injection check valves was inadvertently missed. The licensee is evaluating the need'for increased post maintenance testing of all safety-related motor operated valves (MOVs) to ensure problems such as those identi-fied in IE Bulletin 85-03 (regarding switch setting problems on MOVs) are minimized (Section 8).

The controls / preparations for one observed maintenance activity appeared to be poo A technician was working alone on DC Bus #11 in close proximity to energized elec-trical bus bars. The Interim Reliability Evaluation Program for the plant identi-fled the loss of DC Bus #11 as an initiating event for one of the dominant accident sequences; yet operations personnel did not review the possible consequences of a loss of #11 DC Bus in advance of this maintenance activity. Such action would

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be prudent'_(Section S).

A potential problem with operator informality / documentation follow-through was identified in the area of temporary changes to surveillance procedures. Licensee

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attention should be given to this area (Section 9).

No violations were identifie e60213o127 ADOCK gh37 pga PDR G

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DETAILS Persons Contacted Within this report period, interviews'and discussions were conducted with

.various licensee' personnel, including reactor operators, s maintenance and surveillance technicians and the licensee's management staf . Summary of Facility Activities .

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Unit 1 operated at power throughout the, inspection perio The seals on Reactor Coolant' Pump 11B were kept under close observatio One of the three seals c'esigned:for pump operation'at full system pressure had failed and a second seal had shown signs of. degradation. Criteria were established for unit shutdown should seal degradation continue.- '

Unit'2 was paralleled to the grid following its. refueling outage on December 10, 1985. On December 12 the reactor tripped due to low steam generator level following the loss of #21 Main Feedwater Pump (MFWP) (see Section 5 for de -

tails). The unit returned to power operation later that da On December 16, power was reduced to 60% to repair a cracked coupling on #22 MFW Physics testing was completed on December 26. _The unit continued operating at power for the remainder of the perio . Licensee Action on Previous Inspection Findings (Closed) Inspector Follow Item (318/81-07-02) Licensee to Check that Under-voltage (UV) Device Armatures on Reactor Trip Breakers (RTB) are in the Fully Down Position Following Breaker Closures. This item was in followup to IE Notice 83-76, " Reactor Trip Breaker Malfunctions (Undervoltage Trip Devices on GE Type AK-2-25 Breakers)." The inspector reviewed Surveillance Test Pro-cedures (STPs) in which the RTBs are cycled open and reclosed and the plant startup procedure (OP-5) which directs RTB closure during startup to confirm that proper armature position is checked after closures. In all cases the appropriate check was required and a drawing was included showing proper armature position. Specifically, these checks are required by Step 14, Sec-tion VIII of STP M-2108, "RPS System Logic Test," Revision 25;Section I of STP M-200, ". Reactor Trip Circuit Breaker Functi m al Test," Revision 5; and Step B-5 of OP- (Closed) Unresolved Item (317/83-31-07) Licensee to Audit All Surveillance Test Requirements and Verify Technical Adequacy of Each Surveillance Test Procedure. This effort was completed by the licensee by the end of calendar year 198 (Closed) Inspector Follow Item (318/84-03-02) Installation of Local Position Indicators for the ECCS (Emergency Core Cooling System) Pump Room Ventilation Fan Discharge Damper Appropriate plastic position indicator. signs have been installed in the vicinity of the' dampers on both unit .

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(Closed) Unresolved Item (317/83-31-06) Technical Specification Surveillance Requirement 4.8.1.1.2 (Diesel Generator Load Rejection Test) to be Revised to Reflect Addition o.f Motor Driven Auxiliary Feedwater.(AFW) Pump Which is Now the Single Largest Electrical Load on the Diesels. Technical Specifica-tion Amendments Nos.111 for Unit 1 and 94 for Unit 2 now require, under sur-veillance item 4.8.1.1.2.d.2, testing the diesel generators' capability to reject a load greater than or equal to 500 hp without tripping. This corres-ponds to the load of each motor driven AFW pum . Review of Plant Operations Daily Inspection During routine facility tours, the following were checked: manning, ac-cess control, adherence to procedures and LCOs, instrumentation, recorder traces, protective systems, control rod positions, Containment tempera-ture and pressure, control room annunciators, radiation monitors, radi-ation monitoring, emergency power source operability, control room logs, shift supervisor logs, tagout logs, and operating order No violations were identifie System Alignment Inspection Operating confirmation was made of selected piping system trains. Ac-cessible valve positions and status were examined. Power supply and breaker alignment was checked. Visual inspection of major components was performed. Operability of instruments essential to system perform-ance was assessed. The following systems were checked:

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Unit 1 Steam Generator Blowdown System checked on December 23, 198 Unit 1 and 2 Service Water checked on January 9,198 Unit 1 and 2 Diesel Fuel Oil checked on. January 14, 198 No violations were identifie Biweekly Inspections During inspector plant tours, shift. turnovers were observed; boric acid tank samples and tank levels were compared to the Technicdl Specifica-tions; and the use of radiation work permits and Health Physics proce-dures was reviewed. Area radiation and air monitor use and operational status were reviewe Plant housekeeping and cleanliness were evaluate Verification of the following'tagouts indicated the action was properly conducte Tagout #19231, #11 Diesel Generator checked on January 10, 198 m E

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Tagout #19355, #12 Containment Radiation Monitor Pump checked on January 21, 198 Cold Weather. Protection Previously the NRC inspectors had recommended to the licensee that'they establish a program to ensure that plant components susceptible to ad-verse effects in cold weather would be checked (on a "when. required basis") for. proper protection. During this period,.the inspector con-firmed that such a program was established and being carried out as a periodic maintenance item (in cold weather months) by the operating grou ~

Unit 2 Reactor Physics Testing During the period the inspector reviewed results of the December 1985 Unit 2 startup physics testing program with a fuel cycle management en-gineer. Appropriate testing and measurements were conducted (i.e.,

critical boron concentration, rod insertion times, isothermal temperature and power coefficients, power distribution, shutdown margin, core thermal power evaluation); results met applicable acceptance criteria. No prob-lems were identified. The testing was accomplished under procedures PSTP-2 (Revision 8), " Initial Approach to Criticality and Low Power Physics Testing," and PSTP 3 (Revision 8), " Escalation to Power Test Procedure."

No violations were identified, Other Inspections As of December 27, 1985, a number of scaffolds were erected in the ECCS (Emergency Core Cooling System)-. rooms ~on both unit Identification tags indicated that some of these.(Unit 1) have been up~since April 198 The inspector noted that'a* leg:on-scaffold #9683 was resting on the foundation for #21 Containment' Spray (CS) pump. The leg was within 2 inches of tubing used for the:CS s pumpiseal/ packing air cooling syste This close proximity introduces

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a potentia,1 for pump damage in the event of scaffold movemen The inspector pointed this out to the General Supervisor-0perations (GS-0) and asked if all the scaffolding was necessary in the room. The GS-0 stated he would visit the room and initiate action to get unneces-sary scaffolding remove No violations were identifie . Events Requiring NRC Notification The circumstances surtsunding the'following event requiring prompt NRC noti-fication pursuant to 10 CFR 50.72 were reviewe i

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At 12:39 a.m. on December 12, 1985, Unit 2 tripped on low steam generator level from 46% power due to a loss of the #21 Main Feedwater Pump (MFWP), the only MFWP operating at the time. An erroneous MFWP control signal caused the pump speed to cycle greatly and resulted in a pump trip on high discharge pressure. All plant safety. systems functioned as designed, and steam genera-tor level was restored using the Auxiliary Feedwater System. Troubleshooting revealed a faulty signal selector (2PY4516) and an intermittent erratic con-trol signa The signal selector was replaced and trend recorders were in-stalled at several points in the control system to monitor signals prior to start u The positioner for one feed regulating valve (2CV1111) was later replaced. The erratic signal disappeared and could not be identified or duplicated. The unit was returned to power operation with the pump speed -in manual control. At the close of the inspection period the problem had not recurred. Further troubleshooting is planne No violations were identified.

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6. Observation of Physical Security Checks were made to determine whether security conditions met regulatory re-quirements, the physical security plan, and approved procedures. Those checks included security staffing, protected and vital area barriers, vehicle searches and personnel identification, access' control, badging, and compensatory meas-ures when require .

No violations were identifie . Review of Licensee Event Reports (LERs)

LERs submitted to NRC:RI were reviewed to verify that details were clearly reported, including accuracy of the description of cause and adequacy of cor-rective action. The inspector determined whether further information was re-quired from the licensee, whether generic implications were indicated, and whether the event warranted onsite followup. The following LERs were reviewe LER N Event Date Report Date Subject Unit 1 85-14 11/20/85 12/10/85 Control Room Ventilation Damper Failure Unit 2 85-10 10/19/85 11/18/85 Pressurizer Safety Valve 201 Setpoint out of Specification Unit 1 LER 85-14 was discussed in Section 11 of IR 317/85-31; 318/85-2 Unit 2 LER 85-10 was discussed in Section 5 of IR 317/85-30; 318/85-3 .

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- Maintenance and Facility Change The inspector observed and reviewed maintenance and problem investigation ac-tivities to verify compliance with regulations, administrative and maintenance procedures, codes and standards, proper QA/QC involvement, safety tag use, equipment alignment, jumper use, personnel qualifications', radiological con-trols for worker protection, fire protection, retest requirements, and report-ability per Technical Specifications. The following activities were include MR# PM1-12-6-0-W, Salt Water Sy' stem Flow Verification observed on January 15, 198 Repair of #22 Main Feedwater Pump Coupling observed on December 20, 198 Testing of #11 AFW Pump Speed Governor cbserved on December 24, 198 MR# PM1-36-M-SA-2, AFW Pump #12 Pedestal Holddown Bolt Torque check ob-served on January 9, 1986.*

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MR#M0-205-352-379A,rehl'acsHFArelay'withAgastaton125VDCBus#11 observed on January 10, 198 General Mechanical Maintenance on #11 Diesel observed on January 10, 198 On January 10, 1986, the inspector observed a technician replacing an HFA relay (for annunciation of undervoltage on the #11 125 VDC battery bus) with an Agastat relay. The work was being performed under Mainten-ance Order 205-352-379A and Facility Change Request (FCR)84-002 ~

Since the battery bus could not be deenergized the work had to be done in very close proximity to large, exposed energized busbars. Both units were operating at the time. During the initial period of observation, the Electrical and Instrumentation Modifications Supervisor (E&I Mod. Sup.)

was present and actively involved in the work. After he left, the tech-nician was working by himself near the energized bus work. The inspector

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later left the area and met with the E&I Mod. Sup. The inspector pointed

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out that for personnel safety purposes (electrical shock) it would be wise to have a second individual, properly trained in first aid /CPR, work

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with the technician. The supervisor agreed and stated that normally a QC inspector would be present who could fulfill that function. The supervisor indicated he would take action to supply a second individua The job documentation package showed that QC coverage was being provided at specific hold point Continu'ous QC coverage was not being provided at that tim Subsequently the inspector asked the Unit 1 Control Room Operator if, prior to this maintenance action, he had reviewed the potential problems and equip-ment losses if the #11 DC bus were shorted or otherwise lost due to the main-l tenance action in progress. No such review had been conducted.

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In the " Interim Reliability Evaluation Program (IREP)" for Calvert Cliffs, the loss of DC bus #11 is identified as the initiating event for one of the dominaat accident sequences. Its loss.could result in a trip of both units, failure of the power conversion system (secondary plant), and. degradations of safety systems. The inspector discussed this.with the General Supervisor-Operations (GS-0) and Manager, Nuclear Operations-(MNO)'and. recommended that the above review be conducted for this and;similar. future evolutions (the same job is planned for the remaining DC bu'ses). .The GS-0' stated that he would ensure these types of reviews would be don .

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Post' Maintenance Testing '

Several steps have been tak'en by the licensee toward improving its Post Main-tenance Test Progra In response to Generic Letter 83-28, " Required Actions Based on Generic Im-plications of Salem ATWS Events," on September.6, 1985 the licensee stated it had completed the reviews required by Action Item 3.2.1 and 3.2.2, which were to er.sure that post maintenance testing of all safety related equipment was being performe A Shift Supervisor was appointed to coordinate overall operations and main-tenance activities. A second Senior Licensed individual has been appointed during plant outages to specifically coordinate operations and outage activi-ties.

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to focus additional attention on the post maintenance testing are In September, 1985 Operations Unit Administrative Policy 85-4, " Post Mainten-ante Tcsting," was issued as a uniform set of guidelines to on-shift opera-tions personnel regarding what post maintenance testing should be done for various categories of components and maintenance activit'ie The above policy was in effect during the Fall 1985 Unit 2 refueling outag Early in this inspection period (following the outage) the inspector reviewed post maintenance testing documentation to see if any testing required by this policy had not yet been conducted. He found that four safety injection system check valves (2-51-138, 2-51-128, 2-51-118, and 2-S1-148) had only been par-tially tested'after their hinge pins had been repacked and the gland nuts torqued. Administrative Policy 85-4-(Appendix B-6) correctly called for for-ward flow testing and back leakage testing for these valves. However, the

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Operations Test Documents for these valves only required testing in the for-I ward flow direction (utilizing Surveillance Test Procedure STP-0-65, Section

III'G). The forward flow testing had been accomplished. The inspector dis-l cussed this with the Acting General Supervisor, Operations. The back leakage ,

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tests were immediately conducted with satisfactory result '

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Regarding a related subject, the inspector noted that following maintenance

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on the operators of safety related remote Motor Operated Valves (MOV), Policy 85-4 specifies accomplishment of only a valve stroke timing test and local position' indication tes Recently issued IE Bulletin 85-03, " Motor Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch

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Settings," requires licensees (Action Item d) to prepare or revise procedures to ensure that correct switch settings (i.e. torque, torque bypass, position limit, overload) are determined a'nd maintained throughout the life of the plant. A footnote states that this item is intended to be comt'etely consis-tent with Action Item 3.2, " Post Maintenance Testing," of Generic Letter 83-2 This wording would indicate that additional post maintenance testing should be done, where practicable, to verify proper switch settings. The inspector later learned that the licensee plans to limit the scope of its bulletin re-sponse to only those M0Vs in the High Pressure Safety Injection System which could be called upon to operate under high differential pressure condition The inspector discussed this item with the Manager, Nuclear Operations (MNO)

and the Manager, Nuclear Maintenance (MNM). Because the industry has experi-enced so many problems with MOVs (IEB 85-03 describes a number of these prob-lems) and because the licensee, in their response to Generic Letter 83-28, has committed to adequate post maintenance testing of all safety related equipment, the inspector expressed concern regarding the limited scope of action planned for the problems identified in the bulletin. The actions called for in the bulletin would appear to be appropriate, although possibly to a lesser degree or on a lower priority level, to other safety related MOV Both the MNO and the MNM agreed to further evaluate the issu Licensee ac-tions regarding increased post maintenance testing of other safety related MOVs will be followed by the NRC (IFI 317/85-34-01).

No violations were identifie . Surveillance The inspector observed parts of tests to assess performance in accordance with approved procedures and LCOs, test results (if completed), removal and re-storation of equipment, and deficiency review and resolution. The following tests were reviewed:

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STP #0-7-2 ESF Logic and Performance Test observed on December 26, 198 STP #0-8B Diesel Generator Surveillance Testing observed on January 14, 198 i

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NI Calibration, Unit 2 observed on January 15, 1986. .

ESF Testing On December 26, 1985, during the performance of Surveillance Test Procedure STP 0-7-2 (Engineered Safety Features [ESF] Logic and Performance Test, Revi-sion 36) on Unit 2, operations personnel found that the test button on the l

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I pressurizer pressure (PP) sensor module on cabinet ZD was inoperabl The purpose of the test Sutton is to insert a test signal to trip the PP modul The inspector noted that operations personnel continued with the test proce-dure (Section VII C. of the test) which called for tripping the module by means '.f the test butto Since the button was inoperable, the module was tripped by another mean The module setpoint was temporarily changed as necessary to induce the trip and then restored to its former value. The in-spector questioned this deviation from procedure. General Precaution L. to STP 0-7 states that "if a sensor channel does not trip when the button is depressed it may be necessary to rotate the test level adjusting screw with a screwdriver while depressing the test button until the sensor module trip occurs." The inspector discussed this with the Shift Supervisor and Acting General Supervisor-Operations and pointed out that the test level adjusting screw and the setpoint adjust knob are two different devices and, therefore, General Precaution L. was not applicable. He also pointed out that, prior to continuing the test, a change to STP 0-7-2 should have been appropriately evaluated, in accordance with Calvert Cliffs Instruction 104G (Section VI, I and Attachment 8) to include this alternate means of initiating a module tri Both individuals acknowledged the inspector's comment Further investigation by the licensee showed that operators had appropriately first tried to adjust the test signal level by means of the adjusting screw but were unsuccessful (turned the screw the wrong way) in achieving the proper test signal leve Believing the test signal circuitry to be. inoperable, to complete the test, a change to the procedure to trip the module using the setpoint adjust, was approved by two members of the plant management staff with Senior Operator licenses. .The intent of the procedure was not change After the inspector had discussed the issue with the Shift Supervisor on the day of the event, the change was properly documented. Because all require-ments of TS 6.8.3 (for temporary procedure changes) were ultimately accomp-lished and appropriate SR0 reviews were done in. advance, a citation will not be issued. It is not clear, however, whether the change would have been pro-perly documented had the inspector'not intervened. The GS0 stated that he would counsel all operating shift personnel concerning the need for proper documentation of temporary procedure changes. This formality in making changes / improper documentation of changes could prevent subsequent review, as required by TS's, by the POSRC. This item is' unresolved pending GS0 com-pletion of the above counseling (318/85-34-01).

10. Organizational Changes As discussed in Section 15 of Inspection' Report 317/85-28, 318/85-28, on January 1, 1986 a major licensee reorganization was implemented. A new Nuc-lear Energy Division with four major departments was created. On January 7, 1986 the inspector visited with the various organizational groups and held discussions with personnel in various job positions, ranging from technicians to senior supervisors. Personnel were generally familiar with the new organi-zation of the department to which they were assigned. However, there appeared to be considerable confusion from the working level to the middle management level regarding the organization and personnel assignments in other depart-

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ments. Helpful aids such as new organizational charts and revised telephone directories were not generally available. Responsibilities for some job functions were still being worked'out (e.g., optimal assignment of certain -

surveillance. testing responsibilities). In subsequent discussions with senior management personnel (Manager, Nuclear Operations; Vice President, Nuclear Energy Division; Manager, Nuclear Maintenance; and Manager, Quality Assurance and staff) it was evident that they had a clear sense of direction regarding the reorganization, and they were very positive about the changes. The divi-sion Vice President stated that the senior managers had already developed a-very good working relationshi The General Supervisor, Operations told the inspector later in the period that the new organization's increased resources / efforts in the operations /mainten-ance coordination area were beginning to have positive effects in the effi-

,ciency of scheduling and conduct of maintenan,c Other:than the problems noted above, no adverse consequences (missed surveil-lance tests, etc.) have been noted. Since one of the ultimate objectives of the reorganization is to increase management attention in the nuclear opera-tions area, it should ultimately, yield additional improvement . Radiological Controls - !

Radiological controls were observed on a routine basis during the reporting period. Standard industry radiological ~ work practices, conformance to radio-logical control procedures and 10 CFR Part 20 requirements were observe . 10 CFR 21 Report on Diesel Generator Coinponents On November 26, 1985, Colt Industries - Fairbanks Morse Engine Division pro-vided written notification to the NRC and the licensee regarding possible de-fective nuts used in the assembly of connecting rods and rod bearing cap The suspect nuts were received by Colt Industries through a vendor from April 9, 1984 until the time of notificatio The faces of some of these nuts are not perpendicular to the thread pitch line (within the specified tolerance).

This results in a non parallel fit up of the nut to the mating surface of the connecting rod cap which can cause bending loads on the bolts exceeding design stress limit Colt Industries and the licensee have determined that none of these defective nuts have been installed on the operating diesels at this site. None of the nuts were ordered or added to on-site spare parts storage. Potentially, how-ever, these nuts may be installed in the recently purchased spare diesel en-gin The licensee placed a QC Hold Tag (NCR 5601) on the spare diesel which will remain in effect until the nuts are inspected and replaced as necessar The NRC will follow licensee completion of the inspection and replacement of these nuts on the spare diesel (IFI 317/85-34-02).

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1 Review of Periodic and Special Reports

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Periodic and special reports submitted to the NRC pursuant to Technical Spec-ification 6.9.1 and 6.9.2 were reviewed. The review ascertained: inclusion L of information required by the NRC; test results and/or supporting informa-l tion; consistency with design predictions and performance specifications;

adequacy of' planned corrective action for resolution of problems; determina-l tion of whether any information should be classified as an abnormal occurrence;

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November, 1985 Operations'. Status Reports for.Calvert Cliffs No. 1 Unit and Calvert Cliffs No. 2 Unit,odated December 4, 198 . ' Exit Interview

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Meetings.were periodically held with senior facility management to discuss i

the inspection scope and findings. A summary of findings was pr,esented to

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the licensee at the end of the inspectio ,

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