IR 05000317/1997004
| ML20217R108 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/18/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20217R098 | List: |
| References | |
| 50-317-97-04, 50-317-97-4, 50-318-97-04, 50-318-97-4, NUDOCS 9709040214 | |
| Download: ML20217R108 (22) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
License No DPR 53/DPR-69 Report No /97-04;50 318/97-04 Licensee: Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203 Facility: Calvert Cliffs Nuclear Power Plant Units 1 and 2 Dates: June 1,1997 through July 26,1997 Inspectors: J. Scott Stewart, Senior Resident inspector Fred L. Bower, Ill, Resident inspector Henry K. Lathrop, Resident inspector Gregory Smith, Senior Security Specialist Edward King, Security Specialist Approved by: Lawrence T. Doerflein, Chief Projects Branch 1 Division of Reactor Projects
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9709040214 970818 PDR ADOCK 05000317 0 PDR .
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EXECUTIVE SUMMARY
_ Calvsrt Cliffs Nuclear Power Plant Units 1 and 2 inspection Report Nos. 50 317/97 04 and 50 318/97 04-This integrated inspection report includes aspects of BGE operations, meintenance, engineering and plant support. The report covers an eight week period of resident inspection and includes the results of an announced inspection by security specialist Plant .Coorations The operations department supplemented the operetions shift tun.over process with a '
switch and valve position verification checklist aimed at ensurin0 that critical safety systems were properly aligned. The inspectors considered the checklist verification a good enhancement for ensuring safety system availabilit Two of the four seals for the 11B reactor coolant pump had degraded. Operations and engineering personnel monitored continued seal performance and developed an action plan to ensure that seal degradation did not affect safe plant operation. The inspector considered the actions by operations and engineering personnel to be appropriate for the seal degradation that was observe Maintenance A number of problems with Unit 1 emergency diesel generators were identified during the inspection period. The inspectors considered the BGE actions to evaluate arid correct the problems to be prudent. The inspectors considered that continued BGE attention to problems with the emergency diesel generators was warranted because of the safety .
significance of these systems, Engineerina BGE performed laboratory testing of charcoal samples from plant filter systems in accordance with their established program. However, the inspectors concluded that BGE poorly manag6d their commitment to update the technical specification bases to incorporate the charcoal testing method and did not update the commitment to reflect that a later industry standard was being ued as the test metho BGE initiated a number of actions to improve the reliability and availability of the service water heat exchangers. Some actions, including cleaning of the piping between the saltwater pumps and the heat exchar.gers appeared to reduce heat exchanger fouling. One action to allow removal of a contdnment air cooler from service during transient periods of high bay temperature was bog reviewed by NRC when the inspection period ende Plant Sunoort BGE maintained an effective security program. Management controls for identifying, resolving,' and preventing programmatic problems were effective, audits were thorough, and in-depth. Alarm station operators were knowledgeable of their duties and responsibilities and security training was being performed in accordance with the NRC-approved training and qualification pla ii
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Executive Summary (cont'd)
During a walkdown of plant emergency lichting, the inspectors identified deficiencies that included five poorly aimed lights, evidence of corrosion on a lighting case exterior, and a number of " ready" lights not lit. These lights, with one exception, were determined to be operable. One light had a low voltage condition that required repair by BGE to restore operability. The inspectors found the BGE response to the inspector concerns to be prompt end appropriate. An unresolved item was opened pending evaluation of BGE's corrective actions for previously identified lighting deficiencies and the reliability ci
, emergency lighting during the time between surveillance test .
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TABLE OF CONTENTS ,
EXEC UTIVE SU M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . il TABLE O F C O NT ENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv Summ ary o f Pla nt Statu s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. O p e r a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments ................................. 1 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 08.1 (Clored) LER 50 317/97-004 .......................... 2 11. M a i n t e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 M1 Conduct of Maintenance .................................. 2
M 1.1 General Comments ................................. 2 M1.2 General Comments a Surveillance Activities . . . . . . . . . . . . . , . 3 M1.3 Problems with Emergency Diesel Generators ............... 3 Ill. Engineering ................................................... 4 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 E8.1 Charcoal Filter Testing Requirements . . . . . . . . . . . . . . . . . . . . . 4 E8.2 Update UNR 50 317&318/9 6-06-03 . . . . . . . . . . . . . . . . . . . . . 6 E8.3 (Closed) Violation 50-317&318/95 08-01 ...,............. 7 E8.4 (Closed) Violation 50-317 & 318/9 5-06-02 . . . . . . . . . . . . . . . . . 7 IV. Pl a n t S u p p o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . . 8 S2 Status of Security Facilities and Equipment ..................... 9 S2.1 Alarm Stations and Communications . . . . . . . . . . . . . . . . . . . . . 9 SS Security and Safeguards Staff Training and Qualification ........... 9 S6 Security Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . 9 S7 Quality Assurance in Security and Safeguards Activities . . . . . . . . . . . 10 S7.1 Effectiveness of Management Controls . . . . . . . . . . . . . . . . . . 10 S7.2 Audits ......................................... 11 S8 Miscellaneous Security and Safety Issues ..................... 11 S8.1 Vehicle Barrier System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 S8,2 Review of Fitness for Duty issue . . . . . . . . . . . . . . . . . . . . . . . 12 P1 Conduct of Emergency Preparedness Activities ................. 13 P1.1 Implementation of the New Media Center ................ 13 F1 Status of Fire Protection Facilities and Equipment . . . . . . . . . . . . . . . . 14 F Emergency Lighting Walkdown ....................... 14
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V. Management Meetinge . . . . . . . . . . . . . . . . . . . . ... ................. 15 X1 Exit Meeting Summary . . . . . . . . . . . . . .................... 15 X2 Review of UFS AR Commitments . . ., . . . . . . . . . . . . . . . . , . . . . . . . . 15 ATTACHMENT Attachment 1 - Partial Li::t of Persons Contacted Items Opened, Closed, and Discussed
- List of Acronyms Used
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Report Details Summarv of Plant Status Unit 1 began this inspection period shutdown in Mode 3 due to a leak in a pressurizer pressure instrument sensing line (See NRC inspection Report 50 317/96-03). A reactor startup was commenced on June 1, and the reactor attained full power on June 3,199 Unit 1 briefly reduced power on July 18 for waterbox cleaning, then remained at full power the rest of the inspection perio Unit 2 operated at full power throughout the inspection perio I. Operation _s 01 Conduct of Operations'
01.1 General Comments Following the Unit 1 reactor startup, plant engineers observed that the 11B reactor coolant pump upper seal differential pressure decreased, indicating a degrading upper seal, in August 1996, the 11 B pump lower seal exhibited reduced differential pressure indicating a degraded lower seal. The middle seal remained fully intact and functional. On June 18, based on the changing indications, engineering and operations personnel began daily monitoring of seal pressures and other reactor coolant pump parameters to ensure that changing conditions could be evaluated. An action plan was developed for plant operators in event of rapid degradation of either the middle or upper pump seals. The inspectors were informed that in event of catastrophic failure of the remaining middle seat, a fourth redundant upper seal would retain reactor system pressure until plant cooldown and depressurization could be accomplished. At the end of the inspection period, BGE continued to monitor seal effectiveness and plans for a late summer or early fall outage for seal replacement were made. The inspectors considered the actions by operations and engineering personnel to be appropriate for the seal degradation that was observe During the inspection period, the operations department supplemented the operations shift turnover process with a switch and valve position verification checklist aimed at ensuring that critical safety systems were properly aligned. The checklist was instituted to ensure that safety system mispositionings would be identified during shift tumover and to focus operator awareness on plant safety system alignment. The inspectors reviewed the checklist and verified that operators had implemented the process. The inspectors considered the checklist verification a good enhancement for ensuring safety system availabilit Topical headings such as 01, M8, etc., are used in accordance with the NRC 2 standardized reactor inspection report outline. Individual reports are not expected to address all outline topic l
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08 Miscellaneous Operations issues 08.1 - (Closed) LER 50 317/97 004: Trio Bvoasses Not Removed Above 15 Percent Power The Licensee Event Report (LER) described an occurrence where reactor thermal power was raised above 15 percent without having cleared the axial flux offset and loss of load trip bypass conditions. The inspectors concurred with the BGE assessment that the event had little safety consequence because the problem was recognized as delta T power approached 17 percent and the power was immediately returned to below 15 percent. Reactor power as indicated by nuclear instruments remained below 15 percent throughout the transient, preventing the automatic bypass removal. The cause of the problem involved low gain settings for the nuclear instruments. This setting would normally be adjusted during a reactor downpower, but was not in this case, because the downpower was a rapid downpower due to a reactor coolant leak (See NRC Inspection Report 50 317/97-03). The inspectors verified that procedures were revised to require verification that the bypasses were cleared prior to allowing thermal power to exceed 15 percent for future reactor power escalations. Calvert Cliffs Technical Specification Table 3.3.1, required that the axial flux offset and loss of load reactor protection functions be automatically enabled prior to thermal power exceeding 15 percent. This nonrepetitive, BGE identified and corrected violation is being treated as a Non Cited Violation consistent with Section Vll B.1 of NRC Enforcement Policy, NUREG 160 The licensee event report is closed.(NCV 50-317&318/97-04-01)
11. Maintenance M1 Conduct of Maintenance M1.1 General Comments 4 The inspectors observed all or portions of the following work activities. The j inspectors found that BGE had effectively performed the observed maintenanc Craft personnel demonstrated skillin completing the tasks and supervisors ensured that the work was done correctly in accordance with procedures and policie MO2199605548 Replace Wide Range Noble Gas Monitor Low Range Detector M01199606350 Replace U 1 ECCS Exhaust Fan HEPA Filters MO1199604973 ECCS Pump Room Charcoal Filter Inlet Damper MO1199606487 Inspect Fuel Pool Exhaust Fan Roughing Filters MO2199604151 Repair ECCS Pump Room Watertight Door 104 M01199700774 #11 ECCS Pump Room Air Cooler Anode Replacement
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MO1199700781 #11 ECCS Pump Room Air Cooler Channel Head Inspection MO1199606433 Inspect #11 ECCS Pump Room Air Cooler Duplex Strainer MO1199606432 Clean Tubes on #11 Service Water Heat Exchanger (6/25/97)
MO2199604907 4Kv Bus #22 Meter & Relay inspection M01199703752 Clean #11 Service Water Underground Piping
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M1.2 General Comments on Surveillance Activities (61726)
The inspectors observed selected surveillance tests to detarmine whether approved procedures were used, details were adequate, test instrumentation was properly calibrated and used, technical specifications were satisfied, testing was performed by knowledge 8ble personnel, and test results satisfied acceptance criteria or were properly dispositioned. The inspectors found that surveillance testing was accomplished effectively. The inspectors observed portions of the following surveillance activities and reviewed the test results:
STP-M-567-0 Gaseous and Liquid Waste Discharge Radiation Monitors Calibration Check (Transmitter 0-FT 2192)
STP-M-546-1 ECCS Pump Room Exhaust Filter Test (HEPA)
STP M 547-1 Pump Room Exhaust Filter Test STP-M220G #21 and #24 4Kv Undervoltage Relay Test M1.3 Problems with Emeroency Diesel Generators During the inspection period, a number of mechanical problems with the Unit 1 emergency diesels were identified by BGE On the 1 A engine, on June 3,1997, a jacket cooling pressure switch failed when unidentified raaterial clogged a sensing orifice. This material was not observed in other pressure switches and the clogged switch was replaced. Evaluation of the material to determine the source and composition, continued at the end of the inspection period. On June 17,1997,a handswitch failed preventing operators from manually raising generator loat -The handswitch was replaced. On June 28,1997, a leak was found on a fuel oil pump seal and the leak was repaired. BGE corrected the problems at the time of discovery and none would have prevented the engine from meeting safety-related requirement On the 18 engine, on June 12,1997, starting air tubing to one cylinder cracked and was replaced. Also on June 12, a voltage permissive relay was replaced after it drifted out of specification resulting in unusual generator voltage indication. On June 25,199_7, a motor operated potentiometer was replaced in the speed control circuit, after it :aused an engine trip when tne operators were reducing diesel load following a surveillance tes The BGE operational safety review committee conducted a review of the diesel-problems to identif, any common mode deficiencies or causes. BGF, determined that each problem was isolated. BGE also initiated comprehensive actions to replace copper tubing and relays in the 1B and similar Unit 2 diesels. The inspectors considered the BGE actions to evaluate and correct the problems to be prudent. The inspectors considered that continued BGE attention to repeated
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111. Enaineerina E8 Miscellaneous Engineering issues E8.1 Charcoal Filter Testina Reouirements SCOD_0 The inspectors reviewed the BGE's implementation of the technical specifications (TS) requirements for laboratory analysis of charcoal samples from safety related plant filtering systems, Findinas and Observations The inspectors reviewed the Calvert Cliffs technical specifications for the following systems that use charcoal filters; containment iodine removal (IRU), penetration room exhaust air filtration, control room emergency ventilation, ECCS pump room exhaust air filtration, and spent fuel pool ventilatio Discussions with BGE personnel indicated that the Calvert Cliffs TS had been changed on April 27,1930, to specify lower testing temperatures. The inspectors reviewed the safety evaluation report (SER) dated May 21,1993, for license amendments 142 (Unit 1) and 125 (Unit 2) that changed the temperature at which the laboratory analysis of charcoal adsorbent samples was conducted from 130 to 30 degrees Celsius ( C) for each of the systems listed above except the
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containment iodine removal system. (The inspectors noted that BGE tests the IRU charcoal at both 30 *C and 130 'C) The SER noted that the 30 'C test temperature would be more indicative of accident conditions and would result in more realistic and more consarvative test results than those conducted at 130 ' The SER also noted that NRC Information Notice 86-76, " Problems Noted in Control Room Emergency Ventilation Systems" had described similar findings related to the testing of charcoal. The inspectors concluded that BGE had incorporated information provided in Information Notice 86-7 The inspectors also reviewed the SER for License Amendr. ents 181 (Unit 1) and 157 (Unit 2) that expanded the acceptable methods for obtaining samples from charcoal tilter units. The SER stated, in part, that the amer.dments were found acceptable based on the TS bases being changed to indicate the use of the Idaho
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National Engineering Laboratory (INEL) testing protocol in the submittats for the license amendment request, BGE stated that the INEL testing protocol recommended in NRC Information Notice 87-32, " Deficiencies in the Testing of Nuclear Grade Activated Charcoal" was used in the testing required by the technical specification In a letter to the NRC dated May 7,1993, BGE committed to continue to use the INEL testing protocol and incorporate the information into the appropriate Technical specification bases in the future. The inspector identified that the TS bases had not been changed to reflect this commitment. BGE personnel indicated that a more recent testing standard, ASTM D3803-89, " Standard Test Method for Nuclear-
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Grade Activated Charcoal," that incorporated the INEL Protocol was currently in use at Calvert Cliffs- The inspector was concerned that this commitment had not been incorporated into the technical specification bases and questioned whether this information would be incorporated into improved technical specifications currently being reviewed by NRC. BGE personnel entered this issue into their problem i reporting system and planned to update the technical specification base The inspectors reviewed the test reports and certificates of compliance for each of the air filtration systems on each unit. The inspector noted that each of the samples appeared to meet the acceptance criteria for efficiency. However, the inspector identified two questions. First, the certificate of compliance for the
~ laboratory analysis took exception to the velocity specification for the testin Specifically, the testing was performed at 42 feet per minute (fpm) as required by the purchase specification and the related BGE surveillance test (ST) procedur However, the Calvert Cliffs Final Safety Analysis Report (FSAR) and ASTM D3803-89 require testing at 40 fpm. The inspectors questioned whether this nonconforming condition had been reviewed and evaluated prior to acceptance of the test result. BGE personnel stated that no formal evaluation had been completed regarding this issue but stated that the higher velocity would reduce the residence time of the challenge agent in the test sample. BGE personnel indicated that the reduced residence time would be more conservative measure of charcoal efficienc BGE personnel entered the issue of the conflict between the test specification and the test performance into their problem reporting system and planned to update the surveillance test and purchase specification. The inspectors considered this issue unresolved pending review by a regional effluent inspection specialist. (URI 50-317&318/97 04-02)
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Additionally, the inspectors noted that the TS acceptance criteria for the IRus was specified in terms of elementaliodine whereas the remaining units were specified in terms of methyliodine removal. The inspectors questioned the basis for this difference. BGE personnel stated that they had previously identified that the IRUs were being tested for methyl lodide removal in lieu of elemental iodine removal efficiency. BGE had entered this issue into their problem reporting system. The inspectors questioned whether testing with an attemate challenge agent met the TS requirements. BGE personnel stated that methyliodide was an acceptable and more conservative alternative challenge agent for demonstrating removal efficiency for elementallodine. The inspectors considered this issue unresolved pending review by a region effluent inspection specialist. (URI 50 317&318/97 04-03) Conclusions BGE performed laboratory testing of charcoal filter samples in accordance with their established program. However, the inspectors concluded that BGE poorly managed their commitment to update the TS bases to incorporate the use of the INEL protocol and did not update the commitment to reflect that a later industry standard was being used as the laboratory testing methodology of charcoal filter test samples as part of their test progra _ - _ _ ____ - -
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6 The inspectors concluded that the adequacy of the BGE charcoal testing program was unresolved pending; a regional effluent specialist review of whether the laboratory testing at an elevated velocity acceptably bounded the TS requirement for charcoal efficiency testing; and a regional effluent specialist review of whether methyliodide was an acceptable challenge agent for demonstrating the containment iodine removal units' elemental iodine removal efficienc E8.2 Uodate UNR 50-317&318/96-06-03: Corrective Actions for Diminished Service Water Heat Exchanoer Deslan Maroin Inspection Scooe The inspectors reviewed the BGE activities regarding operability of the service water system during periods of high service water heat exchanger fouiing and high Chesapeake Bay temperature, Findinas and Observations During the inspection period, BGE revised the operating procedure for the salt water system (Operating Instruction 0129) to allow continued operation during some periods of high service water heat exchanger fouling coupled with high Chesapeake Bay temperature. The procedure change included provisions for reducing reactor power in response to increased differential pressure across the service water heat exchangers and/or isolating a containment air cooler for up to 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. The power reduction provided a reduction in plant decay heat and ellowed more margin for service water heat exchanger operability. Likewise, isolating a containment air cooler provided extra margin for emergency diesel operability during plant response to a loss of coolant accident, should the accident occur during a transient hlgh temperature conditio BGE discussed their action plan for dealing with heat exchanger fouling including the procedure changes in a July 15,1997, meeting with the NRC and intended to further discuss these matters in written correspondence to the NRC, At the meeting, BGE stated that their intent in the procedure change was to limit service water heat exchanger out of service time to ensure system reliability during high temperature, high fouling periods. On July 17,1997, NRC Region I requested, via a Task Interface Agreement, the Office of Nuclear Reactor Regulation (NRR) review these matter During the inspection period, BGE cleaned the Uni 1 saltwater piping between the salt water pumps and service water heat exchangers. About 42,000 pounds of bio-mass including barnacles, shells, and other debris were removed in the cleaning. At the end of the inspection period, this cleaning appeared to have effectively reduced macrofouling of the service water heat exchangers, allowed increased saltwater flow at a lower heat exchanger differential pressure, and improved saltwater system reliability by minimiziag the need to clean or bullet the heat exch9nger tubes. BGE also rearranged the !atake structure baffle walls to provide better assurance that
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cooler bay water would be drawn into the plant. This effort also appeared to be effective in ensuring reliability of the service water syste Conclusions BGE had mitiated a number of actions to improve the reliability and availab;lity of the service water heat exchangers. Some actions, including cleaning of the piping between the saltwater pumps and the heat exchangers appeared to be effective in reducing heat exchenger fouling. One action to allow removal of a containment air cooler from service during transient periods of high bay temperature was being reviewed by NR E8.3 1 Closed) Violation 50-317&318/95 08-01. Failure to Ensure that Redundant Trains !
of Systems Remain Free of Fire Damaae The violation involved the failure of BGE to adequately implement fire protection for wall penetrations. The violation was identified during an inspection following a fire which occurred at Calvert Cliffs on April 14,1995. The fire was discussed in Licensee Event Report 50 317/95-04. The inspector verified that the corrective actions discussed in the BGE response to the Notice of Violation were completed, including repair and upgrade of fire barrier penetrations throughout the plant. A number of penetrations not fully repaired because they were inaccessible, were evaluated by engineering as part of the modification package that implemented the repairs. Additionally, a BGE root cause determination was reviewed by the inspectors and the completed corrective actions were discussed with a fire protection enginet.'. BGE actions in response to the notice of violation were appropriate. ~ This violation is eksed, i
E8.4 (Closed) Violation 50-317&318/_95 06-02: Failures of suoervisorv oversicht in the
- control of olant drawinas i The inspectors had identified over 1000 controlled 'frawings in a number of plant locations, including the ontrol room, that were either missing or not the correct revision. Drawing audits did not always use accurate d!stribution lists and werc. not always thorough. The use of check-out cards by plant persontal was inconsisten ,
BGE performed a root cause analysis (RCA) of this issue in July,1995. The ROA identified eight specific causes to the issues surrounding the control of plant drawings, including inaccurate /incompleta documentation, inadequate _ training, procedure non-compliance and inadequate supervision and allocation of resource BGE also determined that there was no actual safety consequence to the out-of-
- revision control room drawings, but the potential exisud for a wide range of
- consequences which could lead to degraded plant / operator performanc BGE implemented severalimmediate and long-term corrective actions. All controlled drawing locations were audited and any out-of-date or missing drawings were updated or replaced, as applicable. The control room storage locations were reduced to three (from five) with distribution changed to enhance operational support, Interdepartmental procedure PR-2-100, " Document and Drawing Control,"
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was enhanced to strengthen control room drawing control and clarify the responsibilities of controlled document users, which was then the subject of a tailgate training session for appropriate personnel. - Appropriate personnel received additional training on procedural requirement The inspectors reviewed copies of the action item tracking system closure documents which summarized the corrective actions taken and, in some cases, their resuks. Based in part on a review of recent issue reports and a limited number of gold cards, the inspectors concluded that BGE's efforts had resulted in a substantial reduction in drawing control issues, especially with respect to the control roo The inspectors found that BGE had been successfulin correcting the issues noted in
) the Notice of Violation. This violation is close IV. Plant Support S 1 -- Conduct of Security and Safeguards Activities Insoection Scoce The inspectors reviewed the BGE security program, including management support and audits; effectiveness of management controls; alarm stations and communications; training and qualification; and the vehicle barrier system, Observations and Findinos The inspectors found that BGE management support was evident based on a generally effective implementation of the security program. The security director position in the organizational structure and reporting chain assured awareness of issues and concerns. BGE management cor.trols for identifying, resolving, and preventing programmatic problems in security were effective, and BGE audits were thorough and in-depth. Alarm station operators were knowledgeable of their duties and responWbilities and security training was being performed in accordance with the NRC-approved training and qualification (T&Q) pla . Based on the inspection of the land vehicle barriers and discussions with security management, the inspectors determined that BGE's provisions for land vehicle control measures satisfied regulatory requirements and licensee commitments. The inspectors also determined, based on discussions with nuclear security officers and supervisors, reviewing applicable procedures, and by performing a physical audit of the security key repositories, that security locke a .J keys were being maintained and controlled as required in the security plan ar.J applicable procedere , Conclusions The inspectors determined that BGE was conducting its security and safeguards activities in a manner that protected public health and safety and that the program, _
as implemented,' met BGE's commitments and NRC requirements,
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9 82 Status of Security Facilities and Equipment S2.1 Alarm Stations and Communications The inspectors assessed the adequacy of the Calvert Cliffs Central Alarm Station (CAS) and Secondary Alarm Station (SAS). Observations of CAS and SAS operations verified that the alarm stations were equipped with the sporopriate alarm, surveillance, and communication capabilities. The CAS and SAS operators were knowledgeable of their detles and responsibilities. The inspectors also verified throu0h observation and interviews that the CAS and SAS operators wera not c required to engage in activities that would interfere with the assessment and response functions, and that BGE had implemented an effective communications plan with the locallaw enforcement agencie Security and Safeguards staff Training and Qualifir an insoection Scoce The inspectors reviewed whether members of the security organization were trained and qualified to perform each assigned security related job task or duty in accordance with the training and qualification plan, Observations and Findinas The inspectors randomly selected and reviewed train'ng . and qualification records for six Nuclear Security Officers (NSOc). Physical and firearms rerpialification records
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were inspected for armed NSOs and security supervisors. The inspectors found that the training had been conducted in accordance with the training and qualification plan and was properly documented. The inspectors alo; observed classroom requalification training addressing the use of pepper spray, and determined that the instructer's presentation was comprehensive and thorough, and that all course material was properly covered. Additionally, tha inspectors interviewed a number of NSOs to deterdne if they possessed the requisite knowledge and ability to carry out their assigned duties, Conclusions The inspectors determined that training had been conducted in accordance with the training and qualification plan. Based on responses to the inspectors' questions, the training provided by the security training staff was found to be effectiv Security Organization and Administration insoection Scong -
The inspectors conducted a review of management support for BGE's physical security progra _ _ ~ =
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10 QhsatyAtlons and Findinas The inspectors revle ved various program enhancements made sinco the last progrom inspection, which was conducted in August 1996. These enhancements included the procurement of three new security vehicles, the hiring of six additional NSOs since the last inspection, and the installation of cardreaders in the warehouse, located outside the protected area, for employee accountability. The inspectors reviewed the Director, Security's position in the organizational structure and reporting chain. Additionally, the inspectors noted that the access authorization program being safeguards related, reports directly to the Director, Security, Conclusigna Management support for the physical security program was determined to be effective. No problems with the organizational structure that would be detrimental to the effective implementation of the sticurity and safeguards programs were note S7 Quality Assurance in Security and Safeguards Activities S Effectiveness of Manaaement Controls 1 Insoection Scone The inspectors reviewed BGE controls for identifying, resolving and preventing programmatic problems, Observations and Findinna The inspectors reviewed BGE controls for identifying, resolving, and preventing security program problems. These controls included the implementation of a departmental self assessment program and the performance of the NRC required annual quality assurance audits. Additionally, the inspectors noted that 13 senior security staff members had received training in the performance of root-cause analysis. BGE also utilized industry data, such as violations of regulatory requirements identified by the NRC at other facilities, as criteria for self assessmen The inspectors reviewed documentation applicable to the performance of the self-assessment program and noted that 50 self assessments were conducted in 1996 and as of this inspection, 26 self assessments were performed during 199 Additionally, the inspectors noted that a number of suggestions directed towards programmatic enhancements were submitted to seeirity management by security personnel. Each issue was appropriately reviewed by security management. The inspectors determined, based on a review of the safeguards event logs, self-assessments and gold card evaluations, that personnel performance errors were minimal.
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11 Conclusions The inspectors concluded that controls were effectively implemented to prevent and resolve potential weaknesse . S7.2 Auditt insoection Scone The Inspectors reviewed BGE's security program audits to determine if committnents contained in the security plan were being satisfied, Observations and Findinas The inspector reviewed the 1996 combined quality assurance audit of the security / access authorization programs, conducted November 7 December 12, 1996, (Audit No. 9614) and the 1996 quality assurance audit of the fitness for-duty (FFD) program, conducted May 9 June 6,1996, (Audit No. 96-07). The audits were found to have been conducted in accordance with the security plan and FFD rul The combined security / access authorization audit report identified one finding and one recommendation. The finding involved a deficiency associated with the vehicle-barrier system installation. The FFD audit identified two findings and four recommendations. The findings involved weaknesses associated with FFD -
procedural distribution and software used for the random FFD testing selection The inspectors determined that the findings were not indicative of programmatic weaknesses, and the recommendations.would enhance program effectiveness. The inspectors determined, based on discussions with security and FFD management and a review of the responses to the findings, that the corrective actions were effectiv C.gngl41@nt Tbn review concluded that the audits were comprehensive in scope and depth, that the findings we,a repotied to the appropriate levels of manageraent, and that the aud.t program was being properly administere Miscellaneous Seevyity and Safety issues S8.1 Vehicle BrioLS.ym.WBS)
- Insoection Scottg The inspector (completed NRC Inspection Manual Temporary Instruction 2515/132,
" Malevolent use of Vehhles at Nuclear Power Plants," dated January 18,1996, and assessed the implementation of.BGE's vehicle control measures, including
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vehicle barrier systems, to determine if they were comtnensurate with regulatory requirements and BGE's physical security plan, Observations and Findinog A February 29,1996,ietter from BGE to the NRC forwarded Revision 34 to its physical security plan that detailed the actions implemented to meet the requirements of 10 CFR 73.55(c)(7) and the design goals for the " Design Basis Land Vehicle" and " Design Basis Land Vehicle Bomb." An NRC August 20,1996, letter advised BGE that the changes submitted had been reviewed and were determined to
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be consistent with the provisions of 10 CFR 50.54(p) and were acceptable fur inclusion in the NRC approved-security pla The inspectors' walkdown of the VBS and review of the VBS summary description disclosed that the as built VBS was consistent with the summary description and met or exceeded the specifications in NUREG/CR 6190, * Protection Against Malevolent Use of Vehicles at Nuclear Power Plants."
The inspectors reviewed BGE's procedures for VBS access control measures, surveillance and compensatory measures. The procedures contained effective controls to provide passage through the VBS, provide adequate surveillance and inspection of the VBS, and provide adequate compensation for any degradation of the VB The inspectors' review of BGE's documentation of the bomb blast analysis determined that it was consistent with the summary description submitted to the NRC. The inspectors also verified that the actual standoff distances provided by their as built VBS were consistent with the minimum standoff distances calculated using NUREG/CR 6190. The standoff distances were verified by review of scaled drawings, Conclusions The inspectors determined that there were no discrepancies in the as built VBS or the VBS summary description. No discrepancies were noted in the documentation of bomb blast analysis or actual standoff distances provided by the as built VB The inspectors' review of the procedures applicable to the VBS disclosed no discrepancie $8.2 Review of Fitness for Dutv Issue The inspectors reviewed a BGE identified fitness for duty issue. The issue involved suspicion of plant security guards that an individual was not fit for duty and actions by plant management in response to the suspicion. The inspectora determined that the security department had acted appropriately and in accordance with the BGE fitness for duty progra _
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P1 Conduct of Emergency Preparedness Activities P1,1 Imolementation of the New Media Center Insnection Scooe 171750)
The inspectors assessed portions of a planned BGE emergency drill, .Qbervations and Findinos BGE performed an emergency preparedness drill on July 10,1997, The drill included the activation and participation of the media conter in Princo Frederick, Maryland. Earlier in 1997, BGE had moved their media center to a now location with enhanced facilities. The inspectors observed a portion of the activities at the media center during the drill and discussed aspects of operation with several drill participant BGE's media conter was recently relocated to the parish house of a local churc The previous center was located at the county fairgrounds. The inspecters noted that the new center was welllit with ample space for responders, members of the public, and news media. Required equipment (telecommunications, etc.) was locked in specially marked wheeled cabinets which were set up in pre planned locations. The inspectors observed that the facility layout appeared effective for the receipt and dispatch of information and that all the equipment was fully functional. BGE informed the inspectors that, for this drill, the center had been pre-activated in order to improve personnel familiarity with equipment setup and operation, and to smooth out any remaining problems related to the recent move into the new buildin The inspectors also observed portions of the mock news briefings issued by a DGE
" spokesman". The area provided for the news media was large and had ample space for the presentation of technical drawings, diagrams and descriptive table The normal business functions performed by church personnel in offices adjacent to the media center rooms did not appear to negatively affect media center operation, Conclusions BGE had successfully implemented the facility change for the emergency preparedness media center, which included several notable enhancement Cmergency response personnel responded effectively to a drill scenario in their receipt and dissemination of informatio .
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F2 Status at Fire Protection Facilities and Equipment F2.1 Ememenev Llahtina Walkdown (71707)
The inspectors walked down a selected sample of Appendix R emergency lights in the Auxiliary Building, the emergency diesel generator room, and the switchgear rooms. The inspectors identified deficiencies that included 'ive poorly aimed lights, evidence of corrosion on a lighting case exterior, a numbar of " ready" lights not lit, and one light that appeared to have low voltage. The inspectors discussed these concerns with BGE system engineering personnel. BGE personnel took prompt action to inspect the concerns and enter the deficiencies into the problem reporting syste All but one of the lights reviewed by the inspector were determined to be operabl The one light with the low voltage was determined to be inoperable due to a f alMd charger and was promptly replaced by BGE. The inspector reviewed the last preventive maintenance inspection of this emergency light that was performed on April 30,1997, and found that the light was verified operable at that tim During the review of the previous test, the inspector noted that the preventive maintenance checklist documented that 17 emergency lights could not be adjusted by craft personnel to aim the light beams on safe shutdown equipment or access pathways. Based on discussions with BGE personnel, the inspector found that the maintenance order to correct these lights had not been worked. BGE personnel did re alm the lights identified by the inspectors. The inspectors considered the number of lights identified as being poorly aligr.ed to be a small percentage of the emergency lights in the plant. However, the inspectors expressed concern that their ability to identify poorly aimed lights and the outstanding maintenance work order (outstanding for over two months) to re align emergency lights may indicate a lack of sensitivity to the importance maintaining safe shutdown emergency lighting properly aligned. BGE personnel acknowledged the inspectvis concern and stated that blackout testing and marking of the lights' alignment were ongoing. BGE expects that the markings will make identifying and correcting misaligned lights casler. The burned out ready lights were scheduled for re lamping and the corroded cases were scheduled for cleaning. No batteries were found corroded or degrade Further, BGE planned to revise the preventive maintenance procedures to check the ready lights and open the cases to inspect for corroclon. The inspectors concluded that BGE took proper corrective actions to address the identified emergency lighting deficiencies. However, evaluation of the BGE corrective actions to previously identified lighting deficiencies and the reliability of emergency lighting during the time between surveillance tests remained unresolved pending further NRC revie (URI 50 317&318/97 04 04)
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L Management Meetinat X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclucion of the inspection on August 7,1997. BGE acknowledged the findings presented. The inspectors asked BGE whether any materials examined during the inspection should be considered proprietary. No proprietary informat!on was identifie X2 Review of UFSAR Commitments A recent discovery of a licensee operating their f acility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR description. While performing the inspections discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspector verified that the UFSAR wording was consistent with the observed plant practices, procedure and/or parameters. Since the UFSAR does not specifically include security program requirements, the inspectors compared licensee activities to the NRC approved physical security plan, which is the applicable document. While performing the inspection discussed in this report, the inspector reviewed Section 4.0 of the Plan, Revision 35, dated July 2,1996, titled, " Keys and Locks." The inspectors determined, based on discussions with nuclear security officers and supervisors, reviewing applicable procedures, and by performing a physical audit of the security key repositories, that security locks and keys are being maintained and controlled as required in the Plan and applicable procedure .
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ATTACHMENTS PARTIAL LIST OF PERSONS CONTACTED BBE P. Katz, Plant General Manager K. Cellers, Superintendent, Nuclear Maintenance K. Neitmann, Superintendent, Nuclear Operations P. Chabot, Manager, Nuclear Engineering T. Pritchett, Director, Nuclear Regulatory Matters ,
B. Watson, General Supervisor, Radiation Safety C. Earls, General Supervisor, Chemistry L. Gibbs, Director, Nuclear Security T. Sydnor, General Supervisor, Plant Engineering J. Lemons, Manager Nuclear Support Services Department J. Holleman, Fitness for Duty Administrator INSPECTION PROCEDUREG USED lP 62707: Maintenance Observation IP 71707: Plant Operations IP 61276: Surveillance Observations IP 37551:Onsite Engineering IP 71750: Plant Support Activities IP 92700: Onside Follow-up of Written Reports of Nonroutine Events IP 92902: Follow up Engineering IP 01700: Physical Security Program for Power Reactors Tl 2515/132: Malevolent use of Vehicles at Nuclear Power Plants ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50 317&318/97 04 02 URI Charcoal Testing Requirements: Velocity may be too high 50 317&318/97 04 03 URI Charcoal Testing Requirements: Removal efficiency does not use elementaliodine 50 317&318/97 04 04 URI Effectiveness of Corrective Actions for Emergency Lighting Deficiencies Closed 50 317&318/97 04 01- NCV LER 50 317/97 004: Trip Bypasses Not Removed Above 15 Percent 50 317&318/95 06 02 VIO Failures of supervisory oversight in the control of plant drawings -
50 317&318/95 08 01 VIO Failure to Ensure that Redundant Trains of Systems Remain Free of Fire Damage Discussed 50 317&318/96-06-03: URI Corrective Actions for Diminished Service Water Heat -
Exchanger Design Margin
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Attachment 1 2 LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable CAS' - Central Alarm System CFR Code of Federal Regulations DP Difforential Pressure EDG Emergency Diesel Generator ESF- Engineered Safety Feature HPCI High Pressure Coolant injection -
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inspection Followup item ISI Inservice inspection IST Inservice Testing LER Licensee Event Report
- MSIV - Main Steam Isolation Valves .
NCRi Nonconformance Report NCV- Non Cited Violation NDE Non Destructive Examination:
NRC Nuclear Regulatory Commission NSO Nuclear Security Officer PA- Protected Area-PSA Probabilistic Safety Assessment PSIG Pounds Per Square Inch Gage-QA Quality Assurance OC Ouality Control SAS Secondary Alarm Station TS Technical Specification
- The Plan- NRC Approved Physical Security Plan UFSAR Updated Final Safety Analysis Report VBS: vehicle barrier system VIO Violation
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