IR 05000317/1978025

IE Inspec Repts 50-317/78-25 & 50-318/78-19 on 780905-08 During Which 2 Items of Noncompliance Were Noted:Failure to Conduct Type B Tests W/In 2 Years,Failure to Follow Approved Procedure

ML20062E012
Person / Time
Site:	Calvert Cliffs
Issue date:	09/28/1978
From:	Higgins J, Tanya Smith, Wong H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20062D992	List: IR 05000317/1978025 ML20062D985 ML20062D995 ML20062E003 ML20062E006
References
50-317-78-25, 50-318-78-19, NUDOCS 7812010303
Download: ML20062E012 (12)

Text

.

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-317/78-25 Report No. 50-318/78-19_

50-317 Docket No. 50-318 DPR-53 C License No. DPR-69 Priority --

Category C Licensee: Baltimore Gas and Electric Company .

P. O. Box 1475 ,

Baltimore, Maryland 21203 Facility Name: Calvert Cliffs Nuclear Power Plant, Units 1 and 2

,

Inspection at: Lusby, Maryland spection conducted: September 5-8, 1978 Inspectors: h o2f 7 /

J C #

, Reactor Inspector date signed

.

'e/v 1/a.s-/74'

T. H. Smith, Reactor Inspector date signed h l Ulm H.JVWorjg, Satjineer/ Intern Y> YW date signed Approved by: [ -

"-

9!2 7f[

. L/ Caiihton Chief, Nuclear Support date signed Secttett No.1, RO&NS Branch

.1spection Summary:

t Inspection on September 5-8, 1978 (Combined Report Nos. 50-317/78-25 and 50-318/78-19) ,

Areas Inspected: Routine, unannounced inspection by re of the Containment Integrated Leak Test report (Unit 1)gional , local based inspectors leak rate i testing, licensee action on previous inspection findings, plant operations, l

tendon surveillance testing (Unit 1), selected licensee events, and the '

inservice test program for pumps and valves. The inspection involved 61 inspector-hours (Unit 1 - 41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br />, Unit 2 - 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />) on site by three NRC regional based inspector Results: Of the seven areas inspected, no items of noncompliance were found in five areas; one item of noncompliance was found in one area (Unit 1)

(infraction - failure to conduct Type B tests within two years, paragraph 4.b)

and one item of noncompliance in another area (Unit 2) (infraction - failure to follow approved nrocedure, paragraph 7.b).

Region I Form 12 (Rev. April 77)

78120103o3!

._ __ ,

.

.

DETAILS Persons Contacted

• M. Bowman, Supervisor QA Audit Unit

• J. Carroll, Performance Engineer

• R. Denton, Supervisor - Technical Support R. Douglass, Chief Engineer S. Jones, Perfonnance Engineer

• J. Lemons, Nuclear Plant Engineer - Maintenance J. Lawson, Instrument Maintenance Shop Foreman W. Lippold, Nuclear Engineer H. McCall, Performance Engineer

• Miernicki, Surveillance Test Engineer J. Mihalcik, Performance Engineer

• L. Russell, Nuclear Plant Engineer - Operations The inspector also talked with and interviewed several other licensee employees during the inspection. They included members of the technical and engineering staff, control room operators, and instrument and maintenance department technician *

denotes those present at the exit intervie . Licensee Action on Previous Insoection Findings (Closed) Unresolved Item (317/78-15-02): The licensee has revised

the index page of STP-0-7-1 to reflect the fact that a portion of the procedure has been removed. This item is resolve (0 pen) Unresolved Item (317/78-15-01): The inspector reviewed procedure OP-6 now in Revision 9. It was noted that OP-6 still references subject matter in STP-0-7-1 which is no longer contained in that procedure. The licensee's representative stated that pro-cedure OP-6 will be corrected prior to September 30, 197 (Closed) Unresolved Item (317/76-09-01): This item is closed based upon inspector review of the documentation of the actual instrumen-l tation locations. The licensee's representative stated that these l locations would be incorporated into Procedure STP No.1-T-1 prior to the next containment integrated leak rate test.

l l

l

!

,

.

.

,

.

(0 pen) Unresolved Item (317/78-09-02): STp No.1-T-3 completed on March 3,1978, had all previous crack patterns attached and was signed off as acceptable. The inspector, however, noted that when comparing the new data with the old that new cracks had appeare Additionally, there was no definitive acceptance criteria in the procedure and the reviewing engineer did not justify the accept-ability of the new cracks. This item remains ope . Containment Integrated Leak Rate Test (CILRT) General

--

STP No.1-T-1, " Integrated Leak Rate Test Unit 1 Contain-ment."

--

" Reactor Containment Building Integrated Leakage Rate Test Report, April 24, 1978."

--

QA Audit No. 16-9-78, performed March 4, 6, and 8, 197 Technical Specification (TS) 3.6. The above references were reviewed for: accurate data trans-cription, proper instrument calibration, proper implementation of procedural changes, correctness of the analytical methods, resolution of the Quality Assurance concerns, and the accurate recording of significant events during the test. No items of noncompliance were identifie Satisfactory CILRT The inspector performed calculations and using raw data in-dependently verified: the proper inclusion of instrument calibration corrections, the computed contained air mass values, the containment leakage rates, and the 95Y confidence intervals. Local leak rate test additions (Type B and C) were verified to be insignificant as compared to the overall CILRT leakage. The test results are presented in Table 1. The inspector's independent calculations agree substantially with the licensee's values and indicate that the CILRT was satis-factorily completed. The inspector had no further question . . . .

'

-

. .

-

.

,

4 Local Leak Rate Testing (LLRT) General

-

The inspector reviewed the LLRT summary portion of the CILRT report and the supporting records and procedures that the i licensee held on site. With the exception of the below items, i the inspector had no further questions in this are ! Type B Test Interval Section III.D.2 of Appendix J to 10 CFR 50 requires Type B tests to be performed during each reactor shutdown for  ;

refueling, or other convenient intervals, but in no case at '

intervals greater than two years. Electrical penetrations,-

however, were not Type B tested during the period November 1973 to March 1976. This is an item of noncompliance (317/78-25-02).  : Record Retention

Technical Specification 6.10.1 and Technical Specification 4.5.B.5 (Technical Specifications in effect prior to Amendmen ) require that air lock leak tests be conducted at intervals .

of six months and that records be retained for five year During review of past testing, air lock leak tests dated October 6, 1976, October 14,1975, April 1975, and October 1974, were not available, but the licensee's representative t stated that tests were performed and that further searching '

! should produce the records. This is an unresolved item - t l (317/78-25-01).

Air Lock Door Seals ,

i The licensee is required by TS 4.6.1.3.a to test air lock

,

~

door seals to a pressure of 15 psig with a precision flow  !

measurement test after each opening. This test is accomplished  ;

using procedure STP M-171. The procedure is performed at a i

>

pressure of 30 psia + 0.2 psi and does not document barometric pressure. Thus, there is no documentation that the 15 psig i test pressure has been met. Additionally, the procedure allows t

,

e

-

l

I

! k

, , , -, ,,,n , _ . - , . . . , , , . n. --..

..e- y . -.. ,

..

.

.

.

R

i

!

.

the option of a pressure decay test vice the required precision flow measurement tes None of completed tests reviewed by the inspector had utilized either the -0.2 psi option or the pressure decay option. This item is unresolved vision of the test procedure and is designated (gending

.tems No re-317/78-25-12 and 318/78-19-12).

e. Air Lock Pa Test

!

The licensee is required by TS 4.G.1.3.b to test the overall air lock to Pa (50 psig) once per six months. In several of

! the tests performed using STP M-471 the licensee nonconserva- !

tively had recorded the leakage as zero, when his instrumentation i

was not sufficiently sensitive to justify this valu The l minimum sensitivity of the pressure decay test can be calculated

,

' using one-half of the smallest division on the pressure gauge, the test volume, and the test tim This item is unresolved pending revision of the procedure to specify use of the test's {

minimum sensitivity when appropriate (Item Nos. 317/78-25-13

!

and 318/78-19-13).

f. Report Errors

!

Ouring the review of the licensee's CILRT report the inspector noted that Penetrations 62 through 69'had. incorrect values reported and that not all of the information required to be reported by Section V.B.3 of Appendix J had been include As

! an example, no mention was made of any air lock door seal

"

tests and not all of the airlock Pa tests were reported. This item is unresolved, pending correction of the report (317/78-25-03).

g. Containment Isolation Valve (CIV) Testing (1) The licensee utilizes STP M-571 for Type C testing of CIV's. Appendix J,Section III.C.1 requires that the test be performed with air or nitrogen. The procedure cautions that the line must be drained of water but does not specify that both sides of CIV's being' tested should be drained and does not give individual draining valve lineups. This item is unresolved pending revision of-the procedure to ensure that all water on both sides of CIV's is drained whenever practicabl ._ - -

__ _ . _ _ ___ _ _ . _ _ . ..

. _ _ _

!

.

.

(2) Procedure STP M-571 has no provision for updating the l Type B and C leakage rate total and verifying that TS 3.6.1.2 for containment integrity is met after maintenance is performed on a CIV. This item is unresolved pending revision of the procedure to require updating of the leakage totals when required. These items relating to

'

STP M-571 are designated (317/78-25-14 and 318/78-19-14).

i 5. Inservice Testing of Pumps (Units 1 and 2)

General The inspector reviewed the following documents relating to the

monthly inservice testing of safety related 1nanps.

--

Letters from BG & E to NRC(NRR) dated June 8, 1978, and August 30, 1978. (Program submittal to NRC)

--

Subsection IWP of Section XI to the ASME Boiler and

Pressure Vessel Code (1974 Edition through Summer,1975 Addenda).

--

Technical Specification 4. STP 0-73-1, " Engineered Safety Feature Equipment Performance Test," Revision 4, dated September 30, 1977.

'

--

STP 0-74-1, " Engineered Safety Feature Equipment Inservice Bearing Temperature Test."

1 --

STP 0-5-2, " Auxiliary Feedwater System," Revision 5,  !

dated March 15, 197 '

The inspector verified that all pumps addressed in the program submittal were tested by approved procedures and that the i

i licensee's program implementation and procedures met applicable requirements. The inspector also reviewed a sampling of test i results over the past six months. With the exception of the

! below items the inspector had no further questions in this a rea.

l l

!

'

.

l

_

.

7 Reference Values The licensee's procedures have no provision for determining new reference values or reconfirming previous values after routine maintenance or repair, as required by Article IWP-3111 of ASME Section XI. This item is unresolved (317/78-25-05 and 318/76-19-05). Bearing Temperatures Article IWP-3500 of ASME Section XI requires that each pump be run until the bearing temperatures stabilize such that three successive readings taken at ten minute intervals do not vary by more than 3%. The STP 0-74 temperature stabilization values exceed the 3% specified. This item is unresolved (317/78-25-06 and 318/78-19-06).

6. Inservice Testing of Valves (Units 1 and 2) General The inspector reviewed the following documents relating to the quarterly inservice testing of safety related valve Letters from BG & E-NRC(NRR) dated June 8,1978, and August 30, 1978. (Program submittal to the NRC)

--

Subsection IWV of Section XI to the ASME B&PV Cod Technical Specification 4. STP 0-65-2, " Quarterly Valve Operability Verification -

Operating," Revision 3, November 3,197 STP 0-66-2, " Quarterly Valve Operability Verification -

Shutdown," Revision 5, November 3,197 STP 0-67-2, " Check Valve Operability Verification,"

Revision 2, November 10, 197 STP 0-68-1, " Refueling Cycle Valve Position Indication -

Test," Revision 1, May 17, 197 .

._ ..

'

-

. .

The inspector verified, on a sampling basis, that all valves addressed in the program were tested via approved procedures and that the licensee's program implementation and procedures met applicable requirements. The inspector also reviewed a sampling of test results over the past six months. With the exception of the below items the inspector had no further

'

questions in this are Retest Results >

'

During the performance of STP 0-65-2 on April 18, 1978, valves SI632 and SW5173 failed their stroke time tests. They were l repaired using approved maintenance requests; however,-retest

!

results with stroke times were not available for review during the inspection. This item is unresolved (318/78-19-07).

t c. Stroke Time Acceptance Criteria

<

Article IWV-3410(c)(3) requires that the test frequency be increased to once per month for those valves whose stroke time has increased a specified amount from the previous test. The

! licensee's procedures have no provision for comparing stroke '

!

times measured with the times recorded during the previous tes This item is unresolved (317/78-25-08 and 318/78-19-08). '

d. Individual Valves Leakage Rates Article IWV-3420(f) requires that the plant owner establish !

maximum permissible leakage rates for individual Category A valves and compare the test results with these acceptance !

criteria. Table IWV-3420-1 gives guidance for establishing these permissible leakage rates. The licensee's procedures currently do not contain individual valve leakage rate accept- l ance criteria. This item is unresolved (317/78-25-09 and ,

318/78-19-09).

a e. Leakage Rate Comparisons

!

Article IWV-3420(g)(2) requires that the leakage rates for ;

! valves six inches or larger be compared with previous test l

results and that the test frequency be increased or valves ,

!

repaired if the margin to the acceptance criteria is below a ;

specified amount. The licensee's procedures have no provision ;

for making these comparisons. This item is unresolved (317/78- '

25-10 and 318/78-19-10).

f l I a

I t

!  !

!  !

i f

- -. ,

i

.

7. Control Room Tour (Units 1 and 2) General The inspector toured the control rooms of both units several times during the inspection to verify that manning requirements were in accordance with the Technical Specifications (TS),

evolutions were being performed in accordance with plant pro-cedures, and that various plant parameters met TS requirements. .

With the exception of the below item the inspector had no further questions as a result of these tours, Safety Injection Tank Levels (Unit 2)

During the control room tour on September 5,1978, at approx-imately 1815 hours0.021 days <br />0.504 hours <br />0.003 weeks <br />6.906075e-4 months <br />, the inspector noted that Safety Injection Tank 21B level was at 200 inches. TS 3.5.1.b establishes the maximum level for operability as 199 inches. TS Action '

statement a requires that the tank be restored to an operable '

status within one hour or the plant be placed in hot shutdown within twelve hours. Upon examining the logs maintained.by the control room operator the inspector noted the tank 21B had been logged as 201 inches during the 0800-1600 shift and as 202 inches during the 1600-2400 shift. Thus, the tank had been inoperable for greater than one hour. There was no circle around the out of specification readings, nor were there any comments as to the reason, as required by Calvert Cliffs Instruction, CCI 114, Attachment (5), step 4. This is an item of noncompliance with Technical Specification 6.8.1, which requires that procedures be implemented (318/78-19-03). Safety Injection Tank 21B level was promptly lowered '

to the allowable band upon identification of the out of specification by the inspector, thus satisfying the Limiting Condition for Operation. During the time of this occu,rence, all of the other three safety injection tanks were within their limits.

! The inspector noted that this event was aggravated by the !

fact that the Senior Control Room Operator for the 0800-1600 !

shift had reviewed the logs as required by CCI 114 without noting any abnormalities and without correction of the high !

level in safety injection tank 21 !

_ _

.

-

.

8. Post-Tensioned Tendon Surveillance Testing General

--

STP No.1-T-2, " Unit 1 Containment Tendon Surveillance,"

July 11, 197 Report of Unit No. 1 Post-Tensioning System Three Year Surveillance - prepared by Bechtel Power Corporation, May 197 Letter from Reid to Lundvall dated May 2,197 Letter from Lundvall to O'Reilly dated January.31, 197 (10 day report)

The inspector reviewed the licensee's tendon surveillance tasting program, including the above references. The NRC is currently reviewing the Three Year Surveillance report and the licensee's Technical Specification change submittal. All outstanding questions relating to this surveillance have not yet been resolved, but are being addressed jointly by the NRC and the license Test Witness The licensee's Five Year Tendon Surveillance Testing Program was in progress during the inspection. The tests were being conducted in accordance with Procedure STP No. 1-T- On September 8,1978, the inspector witnessed a portion of the testing performed on dome tendon 2D21. Preliminary evaluations indicate satisfactory test results. The inspector verified that there was no evidence of corrosion of the tendon anchorage assembly hardware (buttonheads, stressing washer, shims, and bearing plate), the adjacent concrete had no abnormal indications, there were no off size or split buttonheads, the equipment and instrumentation in use were calibrated, and that lift off forces were acceptabl The inspector had no further questions in this area.

l i

. -

, .

-

.

,

RTD Response Time Testing

' During the inspection the inspector witnessed response time testing of spare primary loop resistance temperature detectors (RTD's).

, This testing was being performed in accordance with Procedure Number FTI-121, "Rosemount 104A8H RTD Response Time Check," dated March 13, 1978. The inspector noted that the test was being satisfactorily conducted by qualified personnel and had no further question . Snubber Piston Settings Technical Specification 4.7.8.1.a requires that hydraulic snubbers be determined operable by a visual inspection. The NRC has determined that verification of proper snubber piston setting is an essential element of this inspection to assure operability and hence should be included in the appropriate procedures. The inspector noted that the licensee's program does not require this verificatio ;

'

This item is unresolved (317/78-25-11 and 318/78-19-11).

11. Unresolved Items

,

Items about which more information is required to determine accept-ability are considered unresolved. Paragraphs 4, 5, 6, 9, and 10 of this report contain unresolved item . Exit Interview

!

At the inspection's end the inspectors held a meeting (see Detail 1 for attendees) to discuss the inspection scope and findings. The items of noncompliance and unresolved items were identifie .

'

\ '

i

!

i i

.

,

l l

!

L

. . _ . . . - . . _ . - ..._ .. - . . -- -.._. _.. - . .- -- . _ - .

. __ ._ . .

.

.

.

.

.

Table 1 March 1978 - CILRT Conducted at Pa (50 psig)

at Calvert Cliffs Unit 1 Item Acceptance Criteria Reported Results Inspector's Findings 1. CILRT Leak Rate by Mass --

0.097 %/ Day 0.097 %/ Day Point Technique 2. Upper 95% Confidence Level .75 La = 0.15 %/ Day 0.108 %/ Day 0.106 %/ Day

.on Leak Rate (Mass Point)

3. Supplemental Verification < 25% La 1.5% La 1.5% La Test Differance 4. Type B&C teak Rate Total < .60La = 0.12 %/ Day 0.02 %/ Day 0.02 %/ Day

,

b

_ . _ _ _ _ _ _ _ _ _ _ - _ _