IR 05000317/1986020

Insp Repts 50-317/86-20 & 50-318/86-20 on 861103-07. Violation Noted:Failure to Properly Review Completed Surveillance Tests

ML20214V187
Person / Time
Site:	Calvert Cliffs
Issue date:	11/24/1986
From:	Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214V145	List: IR 05000317/1986020 ML20214V142 ML20214V175
References
50-317-86-20, 50-318-86-20, NUDOCS 8612090561
Download: ML20214V187 (12)

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'U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket / Report: 50-317/86-20 License: DPR-53 50-318/86-20 DPR-69 Licensee: Baltimore Gas and Electric Company Facility: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection At: Lusby, Maryland Inspection Conducted: November 3-7, 1986 Inspectors: S. A. McNeil, Project Manager, P80-8, NRR R. M. Perfetti, Project Engineer, PBD-8, NRR Approved: /(. b A Rf[86 W. E. Tripid Chief, Reactor Projects Section 3A 'Date Inspection Summary: November 3-7, 1986 (Report Nos. 50-317/86-20; 50-317/86-20 Areas Inspected: Special, announced on-site inspection in the areas of plant operations and surveillance programs for (1) containment integrity verification, (2) containment isolation valves and air locks, (3) hydrogen control system, (4) containment spray system, (5) containment cooling system, (6) iodine removal system, and (7) penetration room exhaust air filtration system. Inspection hours totalled 9 Results: One violation concerning the licensee's failure to properly review com-pleted surveillance tests (Detail 4) and two unresolved items were identified:

(1) closure of containment penetration during core alterations and irradiated fuel movements (Detail 3.a), and (2) verification that every containment spray system nozzle is unobstructed (Detail 4.b).

8612090561 861202 PDR ADOCK 05000317 G PDR

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1. Persons Contacted Baltimore Gas and Electric Company

• R. Allen, Principal Engineer, Performance Engineering, NESD

• A. B. Anuje, Principal Engineer, Quality Audits, QASD

• M. E. Bowman, General Supervisor, Technical Services, NESD

• J. E. Branyon, Operations Surveillance Coordinator, NESD 0. P. Bulich, Secondary Systems Engineer, NESD J. Carrol, General Supervisor, QASD

• R. M. Douglas, Manager, QASD M. Finley, Engineer, Licensing, NESD

• R. P. Heibel, General Supervisor Operations, N0D R. Holt, Procedure Development, N0D

• S. Kostelnik, Engineer, Primary Systems Engineering, NESD

• L. Larragoite, Engineer, Licensing, KCSD

• J. R. Lemmons, Manager, N0D

• W. J. Lippold, Manager, NESD J. Lohr, Principal Engineer, Procedure Uevelopment, N00

• C. R. Mahon, Principal Engineer, Primary Systems Engineering, NESD

• J. M. Moreira, General Supervisor E&C, NMD M. Polak, Engineer, Primary Systeas Engineering, NESD

• L. B. Russell, Manager, NMD

• L. E. Salyards, Principal Engineer, Licensing, NESD

• R. B. Sydnor, Senior Engineer, Primary Systems Engineering, NESD

• A. R. Thornton, General Supervisor Plant and Project Engineering, NESD T. J. Unkle, Engineer, Management Systems, QASD M. J. Warren, Engineering Surveillance Test Coordinator, NESD M. L. Wasem, Procedure Development, N0D NRC

• T. Foley, Senior Resident Inspector

• Present at Exit Interview on November 7, 198 . Review of Plant Operations Operational Safety Verification The control room was inspected periodically to verify compliance with minimum staffing requirements, access control, adherence to approved procedures, and compliance with limiting conditions for operation (LCO). Station Tours The inspectors toured accessible areas of the plant including the control room, Unit 1 containment structure, Unit 1 cryogenics room and the tur-bine building. During these tours, observations were made relative to the equipment condition, fire and safety hazards, housekeeping, and

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radiological controls and conditions. No significant concerns were identified ir. these areas. Housekeeping was generally good for a re-fueling outag System Walkdown A walkdown of the Unit 1 Containment Iodine Removal System and Hydrogen Control System was conducted to observe equipment conditions and valve position The inspector noted the following discrepancies with the system lineup OI-41B, Hydrogen Purge System Operation - (Unit 1) Attachment (1A):

(1) a vent valve was omitted from the valve lineup and (2) the location of a test valve described in the lineup was erroneou The licensee was informed and took immediate action to correct the noted discrepancie . Surveillance Activities The inspectors performed an indepth review of the licensee's Technical Speci-fication (TS) surveillance programs for (1) containment integrity verification, (2) containment isolation valves and air locks, (3) hydrogen control system, (4) containment spray system, (5) containment cooling system, (6) iodine re-moval system, and (7) penetration room exhaust air filtration system. The surveillance records reviewed are noted in Attachment A. The inspectors re-viewed the past 6-12 months of records for surveillances that have a perform-ance frequency of quarterly or greater. Additionally, the inspectors examined the records of the previous two performances of each surveillance that is conducted less frequently than every quarte The inspectors noted that the operations surveillance procedures generally were adequately written and performed. In some cases, notably containment integrity verification, these surveillance tests were significantly more con-servative than the TS requirement Conversely, some maintenance surveillance procedures (i.e., instrument calibrations and leak rate tests) were incomplete; some step-by-step procedures did not contain provisions for recording test values required to be measured during intermediate steps of the surveillance, and the results of these measurements were not recorde The following concerns were noted during this surveillance review: During core alterations or the movement of irradiated fuel within the containment, TS LCO 3.9.4.c for Units 1 and 2 requires that each pene-tration providing direct access from the containment atmosphere to the outside atmosphere shall be either closed by an isolation valve, blind flange, or manual valve, or be capable of being closed by an operable automatic containment purge valv TS Surveillance Requirement 4.9. specifies these penetrations to be checked closed at least once per 7 days while in the applicable plant conditions. Section 14.18.3 of the

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y 4 Updated Final. Safety Analysis Report (UFSAR) states that during refueling,.

the containment would be sealed for an inside containment fuel handlin incident except that-it might be open to a penetration room'which is ,

being exhausted to the plant vent through thefcharcoal filters. Addi-tionally,'Section 14.18.1 of the.UFSAR states that the only route for ,

the release of activity to the environment would be.the air drawn across*

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the spent. fuel pool area and discharged to the_ atmosphere through the plant ven ~

Y-Contrary to the above, as the containment penetration room is not'ven-tilated or under negative pressure during these conditions nor is tNe ',

containment penetration room exhaust system required to be operable or - f-demonstrated operable.in mode 6, the following penetrations into.the-containment penetration room apparently present direct access from the containment atmosphere to the outside atmosphere, through the penetration room, but~are not verified to be closed as required by TS Surveillance Requirement 4.9.4.a: - /

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Penetration N Servic O

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ID Postaccident Sample -

11,12 Containment Structure Sump Recirc.Line ~

47A,B,C, Hydrogen Sampling 47D Hydrogen Sampling Return 49A,B,C, Hydrogen Sampling 4 60 Steam to Reactor Head Washdown Area The licensee has committed to (1) resolution of this item prior to the commencement of the Unit 2, Spring 1987 refueling outage and (2) verify-ing these penetrations to be closed at least once every 7 days during -

the current Unit I refueling outag '

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The apparent failure to verify the closure of these containment penetra -

tions during core alterations and irradiated fuel movements shall remain unresolved pending followup (50-317/86-20-01; 50-318/86-20-01).

b. Unit 1 TS Surveillance Requirement 4.6.2.1.c requires that the contain-ment spray system be demonstrated operable for continued mode 1 1 or -

3 operation by performing an air or smoke flow test through each spray header at least once per 5 years and verifying that each spray nozzle

is unobstructe .

l The last performance of the surveillance test procedure, STP M-14.-1,

" Spray Nozzle Test," completed on November 20, 1983, verified tha'.oper-

! ability of 90 spray nozzles on the inner containment spray ring and 89 l nozzles on the outer containment spray ring.

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! Contrary to the above, the actual spray nozzle configuration of the Unit

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I containment spray system is 89 spray nozzles on the inner spray ring l and 90 spray nozzles on the outer spray ring. The last test conducted i

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that. verified the proper. number of spray nozzles for each spray header

+ < was STP M-620-1, " Spray Nozzle Test," completed on May 2, 1979. .The

• r i . maximum interval permitted by TS 4.0.2.a required this. surveillance be

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, completed by-August 2,'1985 (i.e., within 6.25 years from the previous

• _ ,vr date-of completion). Subsequently, Unit 1 has operated in mode 1 from:

. August 4985untilOctober1986. Therefore, the licensee apparently 4 failed to demonstrate Unit 1 containment spray system operability for g' < continued mode 1 operation by not verifying that each spray header nozzle 4- M was unobstructed as ' required,by TS.

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r The licensee.has committed to' resolving this-issue.(' inconsistency) prior

to Unit 1 entering mode 3 fol W dng the current refueling outag *

x Theapparent.failureto_ demon 4ratetheopsEab"111ty.oftheUnit1 con-tainment spray system by verifying that every' spray mozzle in each spray

, header is unobstr6cted shall remain unresolved pending followup (50-317/

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r ' TS Surveillance Requirement 4.6.4.1.4 requirds't' hat 7ha. containment purge 5 ~

isolatio'n valves be demonstrated operable any tima affer,being opened and priof to entering mode 4 from shutdown modes by verifying that.when

~ ,'/ the meas ~ured'1eakage rate -is added to the combined Type / B and C leakage

> ' rate,'the combined leakage rate is <0.60 La (207,600 SCCM). Step 15 of

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STP M-671-1(2) " Containment Purge Isolation Valve Leak Rate Test" for

- Units l'and 2 requires the "as left" leak rate be reforded on the current leak rate sheet in STP M-571-1(2), " Local Leak Rate Test," and that the-total type'B and C leakage be recalculate <

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r Contrary. to the above, the inspectors' review of the five Unit 1 sur-veillances (M-671-1) performed since June 1985 and the three' Unit 2.sur-veillances (M-671-2) conducted since December 1985 found that the/ meas-

, se tir'ed containment purge isolation valve leakage rates were not recorded

" rior was.the total combined type B and C leakage recalculated on the cur-rent applicable leak rate sheet in STP M-571-1(2). The licensee was~

maintaining an unoffidial, unreviewed total type B and'C leakage'.compu-g- , tation for each unit' on a sheet of scrap paper. Thisrindicatedtthat though the licensge,was rit maintaining ttie required',quaJity assurance records-nor following pFocedure, the combined leakage ratJa;was'apparently verified to be <0.60 La when require >

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The licensee immediately implemented corrective actio'n and by the. con-clusion of thF. inspection had completed a draft (revision of STPs H 571-1(2) and Mj671-1(2) to ensure the proper performance'aqd. recording of

..this surveillance requirement. Additionally, the licensee has committed to issuing the final, formal procedural revisioni to ,th'e5a procedures

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by December 7, 198 This will receive inspector followup in subsequent

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6 TS 4.6.4.1.2.c requires that each isolation valve specified_in Table 3.6-1.be demonstrated operable during modes 5 or 6 at least once per 18 months by verifying that upon receipt of the appropriate actuation chan-nel test' signals, each required isolation valve actuates to its isolation position. The purge air inlet valves (CPA-1410-CV and CPA-1411-CV) and the purge air outlet valves (CAP-1412-CV and CPA-1413-CV) are specified in Table 3.6-1 as being required to be verified to close upon receipt of the applicable safety injection actuation test signal The licensee procedures to demonstrate isolation valve operability through instituting test signals on the appropriate actuation channels (safety injection actuation, containment radiation high and containment isolation) are STPs 0-4-1(2), " Integrated Engineered Safety Features Test" and STPs 0-7-1(2), " Engineering Safety Features Logic Test." An inspector review of these Unit 1 and 2 surveillances performed in 1985 and 1986 indicated that contrary to the above, the safety injection actuation of the purge inlet and outlet valves was not being teste As the purge valves are required to be locked shut during modes 1 through !

4 and the safety injection function is applicable only for modes 1 through 4, no violation was cite The licensee has committed to taking appropriate corrective action for the purge valve safety injection actuation surveillance requirements for both Units 1 and 2 prior to Unit 1 entering mode 4 following the current refueling outage. This item will receive inspector followup in subsequent inspection (s). Appendix 104.70 of CCI 104H, " Surveillance Test Program," dated June 1, 1986, provides a cross reference list of the licensee's master surveil-lance test procedures and of the TS surveillance requirements that they satisf A review of this appendix found the cross reference list to be incomplete as in some instances, the appropriate TS requirements were not cross referenced to the proper STPs, either being omitted or impro-perly referenced. For example, STP 0-1 is improperly referenced to TS 4.6.4.1.2.a whereas TS 4.6.1.1.b&c, 4.6.1.8, 4.6.4.1.2.c, 4.6.4.1.3, and 4.6.5.1 surveillance requirements are not cross referenced to any STPs.

1 Licensee actions will receive inspector followup in a subsequent inspec-

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> Completed Surveillance Test Reviews

TS 6.8, " Procedures," states that written procedures shall be established, implemented and maintained covering surveillance and test activities of safety related equipmen Calvert Cliffs Instruction CCI 104H, " Surveillance Test Program," and Quality Assuranca Procedure QAP 1G, " Surveillance Testing," require upon completion of a surveillance test the reviewers (1) verify that the procedure has been properly completed and that failures or deviations from acceptance criteria have been recorded; (2) direct the appropriate corrective action to be taken

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and note such action on the completed surveillance test procedure cover shee Additionally, these procedures state that a test procedure is not complete until all conditions of the test procedure are satisfie The inspector found that the following completed surveillance tests had not

been properly reviewed and that the necessary corrective actions had not been taken for the improper completion and/or failure of the acceptance criteria:

STPs Dates Performed M-380B-0, "H2 Analyzer Calibration 0-AE-6527" December 16, 1985 June 24, 1986 0-28-1, " Hydrogen Recombiner Semi-Annual Test September 18, 1986 0-65-2, " Quarterly Valve Operability October 11, 1986 Verification-Operating" Calvert Cliffs has two hydrogen analyzers which are common to both Units 1 and 2. These hydrogen analyzers must be calibrated at least once every 92 days in accordance with TS surveillance Requirement 4.6.5.2 to demon-strate their operability. Both hydrogen analyzers are required to be operable by TS LCO 3.6.5.1 to permit continued mode 1 or 2 operatio For both the December 16, 1985 and June 24, 1986 performance of STP M-3808-0, the applicable hydrogen analyzer did not meet the calibration acceptance criteria in that the hydrogen concentration meters were out of their specified indicating bands by approximately 0.1-0.2% hydrogen in the non-conservative direction. For neither of these tests did the technician, shift supervisor or the surveillance test coordinator recog-nize that the test results were out of specification. As a result, no corrective actions were taken so both Units 1 and 2 continued 3 months of mode 1 operation following each performance of these STPs with one hydrogen analyzer not meeting the calibration acceptance criteria, T.S. Surveillance Requirement 4.6.5.2.a states that each hydrogen recom-biner shall be demonstrated operable at least once per 6 months by veri-fying during a system functional test that the minimum heater sheath temperature increases to > 700 F within 90 minutes and is maintained for at least two hours. STP 0-28-1 was performed on September 18, 1986 to satisfy this requirement for both No.11 and 12 Unit 1 hydrogen recom-biners. Contrary to the test criteria, both recombiners were operated for only 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 45 minutes at 700*F rather than the two hours re-quire This failure to meet the test acceptance criteria was not noted during the performance or review processe _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - - _ - _ - - - - _ _ - .  !

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As this surveillance had been performed previously on March 18, 1986 and Unit 1 was shutdown on October 24, 1986, neither the maximum allowable surveillance interval of TS 4.0.2.a nor the maximum combined surveillance interval of TS 4.0.2.b were exceeded since the March 1986 performance of the surveillanc STP 0-65-2 is performed quarterly to verify that the isolation times of the containment isolation valves for Unit 2 are within the limits speci-fled by TS 4.6.4.1.3 when tested pursuant to TS 4.0.5 When performed in October 1986, the test was signed as complete on October 7, 198 Yet, portions of the test were not performed until October 9 and 11,198 CCI 104H states that a test procedure is not complete until all condi-tions of the test procedure are satisfied. Neither the technician nor the reviewers noted this test discrepanc The failure to properly review completed surveillances and take corrective action for out of specification test results and/or for improper test comple-tion constitutes a violation (50-317/86-20-03; 50-318/86-20-02).

5. UFSAR Discrepancies Table 5-3, " Containment Structure Isolation Valve Information," and Figure 5-10, " Containment Structure Isolation Valve Arrangements," of the UFSAR are stated to provide the different containment structure isolation valve ar-rangements for each Unit 1 and 2 containment penetration. A review of Table 5-3 and Figure 5-10 indicates that there are apparently numerous discrepancies between this UFSAR information and the actual containment isolation valve arrangements. Of the 73 penetrations provided in Table 5-3, " Containment Structure Isolation Valve Information," 28 of these penetrations have valves listed as part of the penetration which are not treated as containment isola-tion valves for the licensee's TS surveillance requirements. Likewise, the valve arrangements of 21 of the 73 penetrations provided in Figure 5-10,

" Containment Structure Isolation Valve Arrangements," do not reflect the actual penetration valve arrangements in that in each of these 21, actual containment isolation valves are apparently missing from the arrangements provided in the UFSAR.

i The licensee requested that the inspectors provide a written list of apparent l UFSAR Jeficiencies that were identified. A copy of the list provided to the l licensee is provided in Attachment B. The inspector will review licensee followup actions in subsequent inspection (s).

6. Unresolved Items:

An unresolved item is a matter about which more information is required to determine whether it is an acceptable item, a deviation, or a violation. The j following items shall remain unresolved pending followup:

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Unresolved Item 50-317/86-20-01; 50-318/86-20-0 The-failure to verify the closure of all containment penetrations apparently providing direct access from the containment atmosphere to the outside atmosphere during core alterations or the movement of irradiated fuel (Item 3.a).

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Unresolved Item 50-317/86-20-0 The failure to verify by performance of an air or smoke flow test that each spray nozzle in the Unit 1 con-tainment spray system is unobstructed (Item 3.b).

7. Exit Interview The findings of this inspection were discussed with the persons designated in Paragraph 1 on November 7, 198 . Attachments Surveillance Test Procedures Reviewed UFSAR Discrepancies Noted

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ATTACHMENT A SURVEILLANCE TEST PROCEDURES REVIEWED Unit 1 0-4-1 " Integrated Engineered Safety Features Test," Revision 11 0-7-1 " Engineering Safety Features Logic Test," Revision 37 0-28-1 "Hydre jen Recombiner Semi-Annual Test," Revision 3 0-55-1 " Containment Integrity Verification," Revision 28 0-55-A-1 " Containment Integrity Verification (Mode 6)," Revision 11 0-58-1 " Hydrogen Recombiner 18 Month Test," Revision 2 0-60-1 " Containment Purge System Isolation Test," Revision 5 0-62-1 " Monthly Valve Position Verification," Revision 25 0-66-1 " Quarterly Valve Operability Verification-Shutdown," Revision 17 0-70-1 " Staggered Test of "A" Train Components," Revision 6 0-71-1 " Staggered Test of "B" Train Components," Revision 7 0-93-1 " Locked Valve Verification," Revision 20 0-95-1 " Locked Valve Verification Inside Containment," Revision 3 M-14-1 " Spray Nozzle Test," Revision 0 M-171-1 " Personnel Air Lock Seal Test," Revision 6 M-172-1 " Personnel Escape Lock Seal Test," Revision 6 M-471-1 " Air Lock Door Operability & Local Leak Rate Test," Revision 6 M-544-1 " Penetration Room Exhaust Filter Test (HEPA)," Revision 4 M-545-1 " Penetration Room Exhaust Filter Test (Charcoal)," Revision 4 M-548-1 " Containment Iodine Removal Filter Test (HEPA)," Revision 3 M-549-1 " Containment Iodine Removal Filter Test (Charcoal)," Revision 4 M-571-1 " Local Leak Rate Test," Revision 6 M-580-1 "H 2 Recombiner Control Calibration," Revision 4 M-581-1 " Electric Hydrogen Recombiner Inspection," Revision 3 M-671-1 " Containment Purge Isolation Valves Leak Rate Test," Revision 1 Unit 2 0-4-2 " Integrated Engineered Safety Features Test," Revision 13 0-7-2 " Engineering Safety Features Logic Test," Revision 37 0-28-2 " Hydrogen Recombiner Semi-Annual Test," Revision 3 0-55-2 " Containment Integrity Verification," Revision 30 0-55-A-2 "Cor cainment Integrity Verification (Mode 6)," Revision 9 0-58-2 " Hydrogen Recombiner 18 Month Test," Revision 2 0-60-2 " Containment Purge System Isolation Test," Revision 3 0-62-2 " Monthly Valve Position Verification," Revision 23 0-65-2 " Quarterly Valve Operability Verification-Operating," Revision 30 0-66-2 " Quarterly Valve Operability Verification-Shutdown," Revision 23 M-22-2 " Containment Purge Valve Seal Replacement," Revision 0 M-171-2 " Personnel Air Lock Seal Test," Revision 7 M-172-2 " Personnel Escape Lock Seal Test," Revision 8 M-471-2 " Air Lock Door Operability & Local Leak Rate Test," Revision 8 M-571-2 " Local Leak Rate Test," Revision 13 M-580-2 "H 2 Recombiner Control Calibration," Revision 3

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- M-581-2 " Electric Hydrogen Recombiner Inspection," Revision 4 M-671-2 " Containment Purge Isolation Valves Leak Rate Test," Revision 1 Unit 1 and 2 M-380A-0 "H 2 Analyzer Calibration 0-AE-6519," Revision 9 M-3808-0 "H 2 Analyzer Calibration 0-AE-6527," Revision 9

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ATTACHMENT B UFSAR DISCREPANCIES NOTED 1. Table 5.3 UFSAR The following penetrations in Table 5.3, " Containment Structure Isolation Valve Information," reflect valves applicable to their penetrations that apparently are not containment isolation valves:

18, 1D, 2A, 28, 9, 10, 11, 12, 16, 18, 19A, 19B, 20A, 20B, 20C, 37, 38, 39, 44, 47A, 478, 47C, 49A, 498, 49C, 59, 60, and 64 2. Figure 5.10 UFSAR The valve arrangements of the following penetrations provided in Figure 5.10,

" Containment Structure Isolation Valve Arrangements," apparently do not re-flect all containment isolation valves actually in the penetration arrangement:

1A, 18, 1C, 2A, 2B, 10, 11, 12, 13, 14, 16, 18, 23, 39, 41, 60, 64, 72, 77, 78, and 83.

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