IR 05000317/1998012
| ML20207F025 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/04/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207E969 | List: |
| References | |
| 50-317-98-12, 50-318-98-12, NUDOCS 9903110137 | |
| Download: ML20207F025 (22) | |
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s i U.S. NUCLEAR REGULATORY COMMISSION REGION 1 License Nos: DPR-53; DPR-69 l
Docket Nos: 50-317; 50-318 Report Nos.: 50-317/98-12;50-316/98-12 Licensee: Baltimore Gas and Electric Company Post Office Box 1475 Baltimore, Maryland 21203 Facility: Calvert Cliffs Nuclear Power Plant Units 1 and 2 Location: Lusby, Maryland Dates: December 13,1998 through January 30,1999 l Inspectors: J. Scott Stewart, Senior Resident :.1spector Fred L. Bower lil, Resident inspector Tim L. Hoeg, Resident inspector l William Maier, Reactor Engineer, Region i David Beaulieu, Senior Resident inspector, Region I ,
l Approved by: G. Scott Barber, Acting Chief ;
Projects Branch 1 l
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Division of Reactor Projects l I
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9903110137 990304 PDR ADOCK 05000317 G PM .
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EXECUTIVE SUMMARY i Calvert Cliffs Nuclear Power Plant, Units 1 and 2 ;
inspection Report Nos. 50-317/98-12 and 50-318/98-12 l
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This integrated inspection report includes aspects of BGE operations, maintenance, engineering i and plant support. The report covers a seven week period of resident inspection and a review of :
emergency response plan procedures by a regional specialis .
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Plant Operations
An inspector review of operator workarounds found that each issue was scheduled to be resolved within a reasonable time period and there was no significant or cumulative affect on the quality of :'
normal or emergency operations from the issue >
A reporting decision was made incorrectly by a contractor supervisor when a fire watch was l
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conducted twenty minutes after the technical specification allowed time. The problem was ,
identified by BGE during an annual fire protection audit. (F8.1) !
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Maintenance i A station transformer was replaced in a safe, methodical, and professional manner with good risk l
management and supervisory oversigh ,
Preventive maintenance checks identified a degrading steam generator pressure instrument .
power supply prior to failure of the instrument. The power supply was replaced without problem The preventive enecks were established in the maintenance rule goal setting for the 10 CFR 50.65 a(1) instrument power supplies and were successful in preventing repeat instrument failur ,
The inspectors identified that bolting was incompletely installed following work on a service water heat exchanger strainer. The ' work package for the task was poor because multiple action steps and quality verifications were specified within one step and there was no verification that the !
bolting was installed correctly. Checks of the bolting by BGE personnel were incomplete and the strainer was returned to service with loose bolting. When identified, BGE took prompt and comprehensive corrective action BGE identified that a rpare reactor trip breaker had on multiple occasions been placed in service during maintenance without having completed technical specification testing requirements. BGE stated that the event resulted in no significant consequences to public health and safet Enaineerina BGE identified and reported that two battery chargers had been in service withcut having seismic positioners. A seismic event would have made the chargers inoperabl Plant Support BGE radiation protection technicians working in containment acted appropriately when a neutron monitoring instrument showed higher than expected neutron levels. The high readings resulted from the poor material condition of the instrumen l
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TABLE OF CONTENTS EXECUTIVE SU MMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii Sum m ary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. Ope ration s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 O1 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.2 Auxiliary Feedwater System Walkdown . . . . . . . . . . . . . . . . . . . . . . . . 2 I I . Mai nte nance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 M1.1 Gene ral Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 M1.2 ' U1 Salt Water Strainer Guide Ring Installation . . . . . . . . . . . . . . . . . . . 4 M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 M1.3 (Closed) LER 50-317/98-05: Installed Spare Reactor Trip Circuit Breaker (RTCB) lnoperable . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 M1.4 (Closed) Violation 50-317&318/97-08-01 and 97-08-02; and Licensee
,. Event Report 50-317/98-001, Control Element Assembly Position i Indication Out of Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 l li . En ginee ring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 E8 Miscellaneous Engineering Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 E (Closed) LER 50-317/98-004-00 Battery Charger Breakers Missing Seismic Positione r . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 E (Closed) LER 50-318/98-001-00 Inoperable Emergency Diesel G ene rato r . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 I V. Plant S uppo rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . 11 R1.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 R1.2 Neutron Dose Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 P3 EP Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 F8 Miscellaneous Fire Protection Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 F (Closed) LER 50-317&318/98-09: Missed Fire Watch Due to Personnel Error . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 F Brush Fires in the BGE Owner Controlled Area . . . . . . . . . . . . . . . . . 13 V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 X1 Exit Meeting Summaiy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 X3 Management Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
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Executive Summary (cont'd) i ATTACHMENTS l
Attachment 1: Partial List of Persons Contacted inspection Procedures Used items Opened, Closed and Discussed :
List of Acronyms Used j Attachment 2: Emergency Response Plan and Implementing Procedures Reviewed {
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Report Details Summary of Plant Status Both reactors operated at full power throughout the inspection period except for minor power reductions for routine condenser waterbox cleaning and turbine valve testin l. Operations 01 Conduct of Operations 01.1 General Comments (71707)
Plant operations were conducted safely with a proper focus on nuclear safety. The inspectors conducted dai!y reviews of ongoing plant operations and observed that the i overall conduct was professional and safety-conscious. Operators were aware of plant conditions and the status of plant equipment. The operators used effective communications to ensure that evolutions were conducted safely and in accordance with j BGE procedures. Supervisory oversight was appropriat !
On December 14, while completing Technical Specification Surveillance 3.3.1.1, for l thermal margin low pressure protection, operators noted that the Unit 1, Channel A reactor trip pressure setpoint was less that the calculated variable trip setpoint. The surveillance ,
required operators to check the trip pressure twice daily to ensure that the setpoint was )
greater than the calculated value. The variation showed that there was a problem with the low pressure protection calculator in channel A of the reactor protective system. The plant was operating normally at the time and no protective actions were nocessary. The channel was declared inoperable and the appropriate technical specification action was initiated. Following discovery of the problem, instrument and controls (l&C) maintenance .
personnel were informod and troubleshooting commenced. The problem was later !
determined to be an intermittently failed amplifier and the amplifier was replaced. A 1 review of logs by BGE prior to December 14 determined that the setpoint had been lower than the calculated value on December 13, but the discrepancy had been misse j Technical specifications required that operators verify that the calculated pressure be less I than the observed setpoint, or the channel must be placed in either the bypass or trip j condition within one hcur. BGE later determined this missed action on December 13, to i be a violation of technical specifications. An issue report was written and actions were l initiated to document the problem in a licensee event report. Because the LER had not been issued at the end of the inspection period disposition of the apparent violation ,
remained open pending review of the LER by the inspectors. (eel 50-317&318/98-12-01) l On January 15, the inspectors reviewed the status of operator compensatory actions '
(workarounds). BGE maintained a list of outstanding workarounds in the control room and documented the age of each item and plans for correction. BGE operations personnel l periodically reviewed the issues and assessed their cumulative affect on the quality of l normal and emergency operations. There were no issues that affected plant safety and l each issue was prioritized for repair based on safety significance and plant condition l needed for repair Corrective action priority was also assigned based on the significance of each item. The inspector found that BGE was active in identifying and dispositioning operator workarounds in a timely manner. Each issue was scheduled to be resolved
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quality of normal or emergency operations from the issue O1.2 Auxiliary Feedwater System Walkdown ; Insoection Scooe (71707)
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The inspectors performed a walkdown inspection of the eccessible portions of the Unit 1 l auxiliary feedwater (AFW) system.
- Observations and Findings On January 4,' the inspectors walked down various portions of the Unit 1 auxiliary -
feedwater system including the pumps, piping, air operated valves, condensate storage tanks, instrumentation, manual valves, hangers, and piping supports. No visible signs of 1 leakage were noted during the inspection. Piping supports and hangers were inspected for loose bolting and deformation and no deficiencies were found. All of the hangers and supports inspected appeared to be at full strength. Control room indications for the system and local instrumentation appeared to b? In good working order. The assigned system engineer maintained a list of open deficiencies for the system with each material issue being dispostioned as a maintenance work order. The inspectors reviewed the list of open maintenance orders (MO) for the system and found no safety significant issue The inspectors compared the system piping and instrument drawing (P&lD) to the field -
configuration and several discrepancies were noted. Two non-safety discharge header drain line pipe caps were missing. Also, the P&lD incorrectly identified three pump pressure gage isolation valves. The inspectors informed BGE of these findings and an issue report (IR) was written to resolve the discrcpancies, including replacing the caps and correcting the drawing. The inspectors concluded that these issues were minor and had
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no safety impac Conclusions .
The auxiliary feedwater system was found in good material condition and in the correct operational lineup. A few minor discrepancies were identified and BGE responded by placing these issues in their corrective action syste IL Maintenance M1 Conduct of Maintenance M1.1 General Comments a. Insoection Scooe (62707)
The inspectors reviewed maintenance activities for systems and components that were important to safety. Component failures or system problems that affected systems within the scope of the BGE maintenance rule program were assessed to determine if f
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maintenance was effective. Also, the inspectors directly observed all or portions of the following work activities:
MO2199705788 Replace 4kV breaker 152-2113 on Bus 21 MOO 199800409 Acceptance test on new 4 kV breakers MO2199804036 Repair 213 safety injection tank level indication MO2199603982 Replace tubing test connection on 2B EDG Jacket water cooling MO2199900081 Number 23 saltwater pump clean and inspect MO1199703391 Remove and replace 13A 480 volt transformer MO1199900071 Replaced power supply card in U1 ESFAS loss of voltage relay MO1199900304 Replace power supply for 11 steam generator pressure instrument Findinas and Observations
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During the inspection period, maintenance was conducted safely in accordance with BGE procedures and processes. (One exception is noted below in Section M1.2.) The insoectors boserved that work packages were used for safety related work. Quality assurance inspectors were observed at work sites making independent verifications, when appropriate. Good briefings and communications were observed between the work groups, engineering, and operations personne On January 12, the inspectors observed the removal and replacement of a 480 volt transformer in a Unit 2 vital switchgear room. As part of a BGE plant improvement project, some of the older transformers containing polychlorinated-biphenyis (PCBs) were replaced with newer units with no PCBs. The inspectors verified proper electrical tag out boundaries and work document requirements being followed by BGE personnel. The hot work and security permits were reviewed by the inspector and no discrepancies were noted. ' Equipment was re aligned during the maintenance to minimize plant risk. The transformer replacement was performed in a safe, methodical, and professional manner
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with good risk management and supervisory oversigh On January 21, the inspectors identified several fastcaers on the 2A EDG service water heat exchangers supply and return header flanges having less that the BGE specified thread engagement. There was no leakage from the system and system integrity was maintained. The inspectors notified BGE maintenance and an issue report was written to address the condition. In addition, while the maintenance group was evaluating the inspector findings, BGE identified several nuts that were loose and turned freely on the 2A EDG air cooler heat exchanger end bell assembly. BGE wrote another issue report for this issue and the 2A EDG was taken out of service while BGE maintenance corrected the condition. The inspectors considered the BGE response to be prompt with the proper focus on safety. Due to recent bolting issues, BGE initiated a review of bolting to
, . determine what actions may be implemented to prevent future fastener concern During preventive maintenance monitoring of instrument power supplies, BGE identified
- degrading voltage on the power supply for the 11B steam generator pressure transmitte The power supply was declared inoperable, the applicable technical specification limiting
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condition of operation was implemented, and the power supply was replaced without i problems. The activity was observed by the inspectors and discussions were held with the system engineer and instrument maintenance personnel. The inspectors noted that
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4 l instrument power sapplies had been declared a(1) under the Calvert Cliffs maintenance rule program. Goal setting had included establishing a threshold of no insnment failures-due to power supply failures and a preventive maintenance program had been implemented to monitor power supply performance. In this case, the power supply was ;
identified as having degrading voltage output prior to failure of the instrument. The preventive maintenance was therefore successful in detecting the problem prior to instrument failur M1.2 U1 Salt Water Strainer Guide Ring installation i Scope (62707)
The inspectors observed installation of the 11 A and 11B saltwater strainer guide rings and later conducted a system walkdown. Discussions were held with maintenance workers, mechanical assessment personnel, and supervisor g Observations and Findinas l On December 2,1998, BGE engineering personnelidentified that strainer guide rings were missing from all four U1 salt water strainers. The ommission of strainer guide rings increased the probability of macroscopic fouling. This issue was discussed in NRC Inspection Report 50-317&318/98-1 On December 21, the inspectors observed BGE mobile maintenance personnel installing -
flow guide rings on the 11 A and 118 salt water strainers. The maintenance procedure was documented in a BGE maintenance order. The inspectors reviewed portions of the ,
saltwater header tag out for adequate strainer isolation and found the tag out was i appropriate. The !nspectors observed that cleanliness and foreign material exclusion were ;
implemented during the work. The maintenance was performed in a controlled and safe ,
manner and the salt water headers were returned to service later that da l l
On December 28,1998, the inspectors conductad a walkdown of the saltwater system and ;
found that 2 of the 16 flange bolts on the 11 A SW st.ainer inlet flange were loose and less t
, than hand tight. One of the two bolts had approximately 3/4 inch of bolt threads exposed !
between the nut and the outside flange face. The inspectors informed the work control !
center of the finding and BGE confirmed the finding and wrote an issue report. There war.,
no leakage from the system. The loose bolts were_ tightened and the other strainers were !
inspected by BGE to verify similar conditions did not exis ,
The maintenance order provided instructions for reassembly of the strainer housing. The j specific step installed the guide ring, ensured the guide ring was seated prcperly, lowered the strainer into place, reinstalled the flange bolting, and tightened the boltr. There were !
two quality verification hold points associated with the step, including verifung that the l i
controlled drawing was used and that the guide ring was installed !n accordance with the
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drawing. Installation and tightening of the flange bolts was riot verified by quality control personnel and a supervisory walkdown of the flange ir.stallation was not specified. The ,
inspectors considered that the procedure was poor with one procedure step containing so j
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many actions and multiple verifications. Also, there was no evidence of quality verification or supervisory review of the bottin .
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The inspectors considered that the loose bolting was more than a minor problem for the l following reasons: The group that missed the botting had not installed of the strainer guide ring during the 1998 work. In addition, the procedure did not provide a barrier to ensure that the bolting was done satisfactorily prior to placing the system into service, and oversight of the work provided no second check by either supervisors or quality verification )
- to ensure that the bolting was done correctl I i .
I After the NRC inspectors identified the loose bolting, BGE initie.ted a root cause review to )
establish the cause of the problem. BGE halted work by the mobile maintenance group l until training on the event was conducted. Also, BGE mechanical maintenance requested
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additional quality assurance oversight of bolting practices. BGE informed the inspectors ;
that additional actions could be identified from the root cause review. The inspectors also I
- identified a number of minor bolting discrepancies on the 2A emergency diesel generator
, (See M1.1). As a result of these findings, BGE established a protocol for system l engineering, maintenance, and operations personnel to conduct walkdowns of plant ( systems to identify, assess, and correct bolting deficiencie !
Calvert Cliffs Maintenance Procedure MN-1-101," Control of Maintenance Activities,"
- Section 5.8 required maintenance activities to be performed in accordance with the applicable maintenance order. Calvert Cliffs Maintenance Order 1199805606 Step 70 ]
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required flange bolting on the 11 A strainer to be tightened wrench tight. Failure to tighten !
the flange bolting on the 11 A strainer was a violation of Calvert Cliffs Technical
- Specification 5.4.1, which required that maintenance activities be completed in
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accordance with procedures. (VIO 50-317&318/98-12-02). However, because BGE corrected the loose bolting when it was identified, placed the issue in their corrective l action program, initiated a review to determine the cause, and initiated other corrective actions, no response to the Notice of Violation was require Maintenance Conclusions A station transformer was replaced in a safe, methodical, and professional manner with
- good supervisory oversigh Preventive maintenance checks identified a degrading steam generator pressure instrument power supply prior to failure of the instrument. The power supply was replaced without problems. The preventive checks were established in the maintenance rule goal l setting for the A(1) instrurnent power supplies and were successful in preventing a repeat instrument failur The inspectors identified that bolting was incompletely installed following work on a service water heat exchanger strainer. The work package for the task was poor because
- multiple action steps and quality verifications were specified within one step and there was
! no verification that the bolting was installed correctly. Checks of the bolting by BGE personnel were incomplete and the strainer was returned to service with loose bolting.
n When identified, BGE took prompt and comprehensive corrective actions.
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6 l M1.2. Routine Surveillance Observations Inspection Scope (61726)
The inspectors observed all or portions of the following surveil!ance tests: !
STP-M-200-1 Reactor Trip Circuit Breaker Test Unit 1 L STP-O-64-2 Safety injection Tank Operability Verification l STP-M-200-2 ReactorTrip Circuit Breaker Test Unit 2
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STP-O-47B-1 Unit 1 Main Steam isolation Valve Partial Stroke Test STP-M-171-2 Unit 2 Containment Personnel Air Lock Test STP-O-5A-2 Auxiliary Feed Water Pump Operability Test STP-O-731-1 High Pressure Safety injection Pump Operability Test )
- STP-O-33-2 Containment Radiation Monitor Monthly Test 1 1 Observations and Findinas -
l The inspectors found that the selected surveillance activities were performed safely and in l_
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accordance with approved procedures. Test details were discussed at a pre-test briefing I
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that typically included a question and answer session attended by all test participants. The ,
inspector found that test participants were knowicdgeable of their assigned ,
responsibilities. Supervisory and system engineering participation was observed in the ,
conduct of the surveillance test '
The inspectors observed that minor discrepancies noted during the tests were properly -
entered into the BGE corrective action system and promptly resolve ) Conclusions
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Surveillance testing was done in accordance with BGE procedures. Supervisory and 1
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system engineering personnel participated in surveillance testin : M1.3 (Closed) LER 50-317/98-05: Installed Spare Reactor Trip Circuit Breaker (RTCB)
Inoperable
- Inspection Scooe The inspectors conducted an onsite review of a Licensee Event Report (LER). Findinas and Observations BGE identified that a spare reactor trip circuit breaker installed during maintenance on the normal breaker, did not meet the surveillance requirements of Technical Specification 3.3.1.1. Reactor trip breakers were required to undergo a channel functional test monthly and a time response test each refueling interval. The spare breaker met only the time response requirement. The monthly functional test was not performed. The occurrence l
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resulted in no consequences to public health and safety and was of low risk becausa the L installed spare remained backed up by a fully tested breaker.
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The BGE root cause concluded that incomplete guidance was provided to maintenance !
personnel and technical specifications were not properly assessed when using the spare i breaker. Corrective included training of maintenance personnel and procedure changes t
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establishing the required testing for use of spare RTCBs. The inspector verified that BGE procedure FTE-57 "RTCB Maintenance" was revised to include functional testing of the
spare breaker. The use of the spare reactor trip breaker without meeting technical specification testing requirements was a violation of Technical Specification 3.3. However, because the issue was identified by BGE, was not willful, was corrected in a >
timely manner, and was not repetitive, the violation was not cited in accordance with i Vil.B.1 of NUREG-1600, NRC Enforcement Policy. (NCV 50-317&318/98-12-03) The i LER was close .
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BGE identified that a spare reactor trip breaker had on multiple occasions been placed in i service during maintenance without having completed techr?al specification testing I requirements. BGE stated that the event resulted in no signtiscant consequences to public ,
health and safet M1.4 (Closed) Violation 50-317&318/97-08-01 and 97-08-02; and Licensee Event Report 50- !
317/98-001, Control Element. Assembly Position Indication Out of Sennce i l
On January 4 and 5,1998, following reactor moderator temperature coefficient testing on l Unit 1, following questioning by the inspectors, BGE identified that a condition prohibited -
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by technical specifications had occurred. The details of the occurrence were described in NRC inspection Report 50-317&318/97-08 and Licensee Event Report (LER) 50-317/98-001. Two NRC Notices of Violation were issued to BGE in the 1997 inspection repu BGE responded to the violations in a letter to the NRC, dated June 10,1998. During onsite inspection, the inspector reviewed the BGE root cause evaluation of the occurrence which found that the power supply voltage had drifted and changed the control element assembly (CEA) position indication. The drift had been aggravated by an initial high voltage setting and wac not recognized because of numerous problems with position indication. The inspector verified the BGE corrective actions which included replacing the primary CEA position computer cards on both units, and revising the appropriate maintenance and surveillance procedures to periodically calibrate and monitor the power supply voltage. The risk significance of the occurrence was low due to the rods remaining in the correct position throughout the occurrence. The violations and the LER were j close j i
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111. Enaineerina E8 Miscellaneous Engineering issues 1
E (Closed) LER 50-317/98-004-00 Battery Charger Breakers Missing Seismic Positioner 4 Scooe (92700) '
The inspectors conducted an on-site review of a Licensee Event Report (LER). Qhservations and Findinas On March 3,1998, BGE determined that the No.13 Battery Charger 480-volt supply
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breaker was missing a seismic positioner. ' On March 9,1998, BGE found that the No.14 Battery Charger 480-volt supply breaker was also installed without the required seismic positioner. BGE informed the inspectors that the seismic positioners were provided to give lateral support to the breakers during a seismic event.. As stated in the LER, the vendor stated that the breaker would be susceptible to damage in a seismic event without the positioner being installed. At the time of discovery both units were operating at 100 percent powe BGE personnel conducted an event investigation and concluded that the seismic -
positioner had never heen installed on either breaker. BGE also concluded that the breaker position indication and high voltage trip would probably be inoperable after a design basis seismic event.
Technical Specifications (TS) required that all DC busses be operable, including the
. ' associated battery and one battery charger, in operational modes 1 through 4. A similar requirement existed in modes 5 and 6. . Since the 13 and 14 battery chargers were not seismically qualified since installation, the redundant 21 and 22 battery chargers could not be removed from service for more than two hours without violating technical specification The BGE event investigation did not perform an exhaustive search to identify all occasions
. when the redundant chargers were out of service; however, the investigation report did document that technical specification violations had occurre The BGE corrective actions included: (1) inspecting all safety-related Westinghouse 480-volt circuit breakers to ensure that the seismic positioners were installed; and, (2) ;
changing the preventive maintenance procedure for the Westinghouse 'DS' style circuit breakers to verify that these seismic positioners were always installed on the circuit breakers. The event investigation report documentec that BGE completed the inspection of the breakers and determined that no other seismic positioners were missing. The inspectors reviewed electrical mainterance technical procedures, FTE-52,480V Load Center Circuit Breaker and Cubicle inspection for DS-4f 6 Breakers, and FTE-53,480V
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Load Center Circuit Breaker and Cubicle inspection for DS-206 Breakers. The inspectors noted that these procedures had been revised to verify that the seismic restraints were
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The inspectors noted that the affected DC busses could be affected only if a seismic event l occurred and the redundant battery chargers failed or were out of service. Therefore, the i inspectors considered this event to be of low risk significance. Additionally, a regional ;'
Senior Reactor Analyst performed a risk assessment of this event and concluded that this event was not risk significant due to the time available to replace the inoperable breaker, the low frequency of an earthquake, and the low probability of damage or unavailability of ;
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the redundant breaker. Therefore, this non-repetitive, licensee-identified and corrected ;
violation was treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC
- Enforcement Policy. (NCV 50-317&318/98-12-04) The LER was close .{
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. Conclusions BGE identified and reported that two battery chargers had been in service without having seismic positioners. A seismic event would have made the chargers inoperabl t E (Closed) LER 50-318/98-001-00 Inoperable Emergency Diesel Generator
' Scope (92700) ,
The inspectors conducted an on-site review of a Licensee Event Report (LER). Observations and Findinas On January 13,1998, BGE identified that the 2B emergency diesel generator had been inoperable for 15 days. BGE determined that a speed switch adapter failed during a surveillance run on December 29,1997. For this condition, BGE concluded that the diesel probably would not have achieved voltage and automatically closed the output breaker _ !
within 10 seconds as designed had a loss of power occurred. During the surveillance test, operators noticed a loss of speed signal. As stated in the LER, BGE initially suspected a l failed tachometer generator and took no immediate corrective action. Subsequently, a surveillance test failed on January 12,1998, and BGE identified that the speed switch ,
adapter had failed, causing loss of local speed indication. Both Units were operating at 100 percent power when the discovery was mad For corrective actions BGE (1) inspected and replaced the other diesel speed switch adapters to ensure spring clips were not degraded; (2) implemented preventive maintenance inspection of diesel generator speed switch adapter spring clips; (3)
performed a root cause on the depth of analysis and communicated the results to other engineering personnel; (4) evaluated alternate speed switch adapter designs which did not
. require the use of a spring clip; and, (5) supplemented the existing information on the speed switch adapter in the diesel technical manua The inspector reviewed BGE records and concluded that the speed adapter switches were replaced on the 1B and 2A diesels. The inspectors also reviewed a selected sample of
. training records and verified that the training was provided to plant engineering and maintenance personne . - .
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i Plant engineering personnel evaluated alternate speed switch adapter designs and recommended replacing the current mechanical speed switch adapter, speed switch, and :
tach generator units with electronic speed pickup units that did not require the use of a i spring clip. This modification was scheduled for installation during the 2002 and 2003 l outages. . BGE also updated the vendor technical manual with additional information ;
available from the vendor to supplement the existing information on the speed switch adapter. At the time of the inspection, BGE had not implemented preventive maintenance insp6ction of diesel generator speed switch adapter spring clips. The system engineer stated that this preventive inspection was not needed for two years from the prior inspection. An inspector follow-up item (IFl 50-317&318/98-12-05) was opened to verify implementation of the spring clip preventive inspection.-
An NRC safety system engineering inspection team was onsite in January 1998 and reviewed this event. The details of this review were documented in NRC Inspection
'ieport 50-317&318/98-80. The team concluded that BGE troubleshooting efforts were not detailed enough to properly identify a failed speed switch which was identified by the unsuccessful post-maintenance test. The NRC team also concluded that BGE actions represented instances of inadequate corrective actions that were cited as a violation of NRC requirements (VIO 50-317&318/98-80-05). BGE responded to the Notice in a letter dated May 14,1998. The inspector found that the corrective actions identified for the violation were the same as those for the LER and the violation is close A regional Senior Reactor Analyst (SRA) performed a risk assessment, calculated a conditional core damage frequency and concluded that this event was of low risk significance. - The SRA noted that if the other EDG or equlpment that the 2A EDG powered had been out of service during the 15 days, or had an offsite power source been out of service, then the risk could have been significantly increased. Through a review of control room logs, the inspectors verified that the offsite power remained in-service during the 15 day period. The inspectors noted that the 2A diesel and some associated redundant safety equipment were removed from service for surveillance testing. However, the inspectors confirmed that the 2A EDG and the associated safety equipment remained functional and could have been aligned to perform their safety function. As noted in the LER, the 28 emergency diesel output breaker could have been manually closed or the station blackout diesel generator could have been used. The inspectors concluded that i the risk significance of this event was low. The LER was close Conclusions l BGE found that the 2B Emergency Diesel Generator had been inoperable for 15 days )
after the speed adapter switch failed during a surveillance run. The associated LER was close '
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R1 Radiological Protection and Chemistry (RP&C) Controls R1,1 General Comments
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l On January 11, the inspectors reviewed BGE's chemistry records associated with receipt
of safety related grade fuel oil. -The inspectors determined that the receipt analysis was performed in accordance with BGE procedures and documented accordingly. The fuel oil received met the BGE specifications.
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The inspectors observed portions of the high radiological risk evolution, spent fuel pool diving for refueling equipment maintenance. In these observations, the inspectors confirmed that the special work permit requirements were fully implemented and workers ,
were knowledgeable of their responsibilities. The inspectors observed good supervisory ~ $
oversight of the tasks.- No problems were identified by the inspector R1.2 Neutron Dose Monitoring i Insoection Scope (83750) .
A review was performed of radiological controls employed for a December 29,1998 entry into containment during power operations. Information was gathered by observations of activities associated with the December 29,1998 entry into the Unit 1 containment, review of calibration records, and interviews with cognizant personne Findinas and Observations E On December 29,1998, a chemistry technician and a health physics (HP) technician made a routine entry into the Unit 1 containment during power operations to obtain a sample from the safety injection tanks (SITS). Historical survey records showed that neutron dose rates in the work area were approximately 40 mrem /hr neutrons, gamma dose rates in the area were 10 mrem /hr gamma, the typical job duration to perform this task was 10-12 minutes, and typical accrued dose to perform this task was about 10-15 mrem per individual. The radiological survey instrument selected to measure neutron dose rates was a Ludium-12/Remball. Pre-operational checks performed on the
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survey instrument including a visual inspection to determine if there were any obvious signs of physical damage, a bettery check, and a source check with a Pu-Be source indicated that the instrument was in generally good condition and operating properly prior to use. During the containment entry the health physics (HP) technician noted erratic .
s readings on the neutron survey instrument including neutron dose rates in excess of the
' 600 mrem per hour limit as authorized by the special (radiation) work permit. The HP technician terminated the entry and both workers immediately exited containment. BGE
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performed a post event critique to evaluate _ the circumstances of the event, reasons for the erratic instrument readings, and radiation dose received by the individuals involve Radiologically controlled area access authorization was suspended for the individuals L involved during processing of personal radiation monitoring devices (thermoluminescent dosimeters {TLDs}). Results from TLD processing showed that doses received by the y
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one screw was missing, another screw was broken, and several screws were loose. BGE concluded that the cause of the erratic readings was due to problems with the screws that secured the electronics within the instrumen The inspector discussed remball calibration with the Radiation Protection Manager.
i Licensee staff had data that indicated the readings of both the TLDs and the remball were conservative (greater than actual) at low neutron energies (e.g.,1-5 kev). The radiation protection manager stated that a TLD and remball neutron response study was performed in December and the results were documented in a written standing order. That study showed that the TLD response was greater than the remball response by a factor of about 1.8 to 1.9.~ Consequently, a correction factor (CF) of two was established to modify the remball response to match the response of TLDs at low neutron energies. The RPM also stated that prior to December of 1998, a neutron response CF of 1.5 had been used with the remball, but the technical basis for the CF was not formally documented. The
- radiation protection manager stated that issue reports were initiated to investigate 1) the I circumstances associated with the termination of the December 29,1998 containment entry,2) the faulty condition of the neutron survey instrument, and 3) the response of TLDs and the PNR-4 remball to neutron radiation. An inspector followup item was opened to review the use of correction factors used to modify the readings of portable neutron radiation survey instruments and to review policies and practices for the performance of pre-operational checks of radiological survey instruments. (IFl 50-317&318/98-12-06) Conclusions l
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BGE radiation protection technicians acted appropriately to terminate a December 29, l
1998 containment entry during power operations when a neutron radiation survey l Instrument showed erratic readings. Licensee staff determined that erratic readings of the i neutron radiation survey instrument resulted because of poor material conditions of the
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P EP Procedures and Documentation l
l The inspectors reviewed, in the NRC Region I office, recent changes BGE made to their l l emergency plan and associated implementing procedures. Based on BGE's t
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determination that the changes did not decrease the overall effectiveness of its emergency
! plan, no prior NRC approval was required in accordance with 10 CFR 50.54(q). After a limited, in-office review of the changes, the inspectors concluded that the changes were -
L made in accordance with the provisions of $50.54(q). A list of the changes reviewed are included as an attachment to this repor l
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F8 Miscellaneous Fire Protection issues 1 F (Closed) LER 50-317&318/98-09: Missed Fire Watch Due to Personnel Error j a.' Insoection Scope The inspector conducted an on-site review of a Licensee Event Report (LER). Findinas and Observations The BGE (LER) described an occurrence where an hourly fire watch for two adjoining safety related emergency diesel generator rooms was completed twenty minutes lat BGE stated that the cause of the late fire watch was distraction of the assigned individual and inattention to detail.- The safety consequence of the occurrence was low because no hot work was ongoing at the time of occurrence and both fire detection and automatic fire suppression equipment in both diesel rooms remained in service. During the onsite inspection, the inspector verified that the training discussed in the LER had been either completed or was planned. The late fire watch was considered a minor violatio BGE also identified in the LER that the late fire watch, although promptly identif:ed in the BGE corrective action program, was not reported to the NRC within 30 days of occurrencc, as required by 50.73(a)(2)(B). Reportability of the issue for a missed technical specification action was identified during a fire protection audit conducted in -
December 1998. The inspector reviewed the initial BGE issue report and learned that the reviewing supervisor for the issue was a contractor supervisor, rather than a regular BGE
. employee. The inspector was concerned that BGE contractor cupervisors were not - I trained on making operability or reportability decisions for BGE. Failure to report the missed fire watch action within 30 days of occurrence was a violation of 10 CFR 50.7 i Because the issue was identified by BGE and entered into their corrective action system, !
- and because it was neither a repetitive nor willful issue, the issue was considered non-cited in accordance with Vll.B.1 of the NRC Enforcement Policy. (NCV 50-317&318/98-12-07) Conclusions A reportability decision was made incorrectly by a contractor supervisor when a fire watch was conducted twenty minutes after the technical specification allowed time. The problem was identified by BGE during an annual fire protection audi F Brush Fires in the BGE Owner Controlled Area On January 12 and 13, BGE experienced brush fires in the owner controlled area outside of the protected area. The fires took place at the BGE recreational facility adjacent to the power plant. The brush fires were small and ' extinguished by the BGE fire department with i no threat to the protected area. BGE security and fire departments responded 1
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appropriately and extinguished the fires quickly.
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V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors with Mr. G. S. Barber of NRC Region I in attendance, presented the preliminary inspection findings to members of BGE management at the conclusion of the inspection on February 17,1999. BGE acknowledged the preliminary inspection finding X3 Management Meeting Summary On January 29,1999, NRC Commissioner Jeffrey Merrifield and members of his staff, .,
accompanied by the NRC Region I Administrator and the resident inspectors, toured !
Calvert Cliffs and met with BGE management. The meetings included general discussions of plant performance and other regulatory issue ]
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I Attachment 1 PARTIAL LIST OF PERSONS CONTACTED BGE C. Cruse, Vice President - Nuclear Energy Division P. Katz, Plant General Manager K. Cellars, Manager, Nuclear Engineering .
L. Wechbaugh, Superintendent, Nucicar Maintenance M. Navin, Superintendent, Nuclear Operations B. Montgomery, Director, Nuclear Regulatory Matters l S. Sanders, General Supervisor, Radiation Safety )
T. Sydnor, General Supervisor, Plant Engineering :
D. Holm, General Supervisor, Plant Operations i T. Pritchett, Superintendent, Technical Support l L. Smialek, Radiation Protection Manager !
J. Lemons, Manager, Nuclear Support Services Department l T. Forgette, Director, Emergency Planning Unit I i'
NRC H. Miller, NRC Region 1 Administrator i
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INSPECTION PROCEDURES USED IP 71707 Plant Operations IP 62707 Maintenance Observation IP 61726 Surveillance Observation IP 92700: Onsite Follow up of Written Reports at Power Reactor Facilities IP 37551: Onsite Engineering IP 71750: Plant Support Activities IP 82701: Operational Status of the Emergency Preparedness Program
LIST OF ACRONYMS USED AFW Auxilary Feedwater CEA Control Element Assembly EDG Emergency Diesel Generator ENS Emergency Notification System l&C Instrument & Controls IR issue Reports LER Licensee Event Report MO Maintenance Orders NEF Nuclear Engineering Facility OSC Operational Support Center PCBs Polychlorinated-biphenyls P&lD Piping and Instrument Drawing PDR Public Document Room RMS Radiation Monitoring System RP&C Radiological Protection & Chemistry Controls RTCB Reactor Trip Circuit Breaker
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! Attachment 1 2 l SIT Safety injection Tank SRA NRC Senior Reactor Analyst S Salt Water
.TLD Thermoluminescent Detector TS Technical Specifications l
l ITEMS OPENED. CLOSED Opened
! 50-317&318/98-12-01 eel Missed out-of-specification log reading during operator rounds was an apparent violation of technical specification &318/98-12-05 lFI Verify preventive inspection of diesel generator speed switch adapter spring clip =j
50-317&318/98-12-06 IFl Review use of the two factor for neutron dose estimates Opened / Closed 50-317&318/98-12-03 NCV A spare reactor trip breaker had been temporarily placed in service without completing technical specification testing requirements 50-317&318/98-12-02 VIO Failure to tighten the flange bolting on the 11 A service water strainer in.accordance with maintenance procedures
'50-317&318/98-12-04 NCV Two station battery chargers were in service without seismic positioners, contrary to technical specifications
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50-317&318/98-12-07 NCV Failure to promptly report a missed technical specification action - Missed fire watch Obsed 50-317&318/98-80-05 VIO Failure to identify and correct problems with a diesel speed
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--50-317/98-05 LER installed Spare Reactor Trip Circuit Breaker inoperable 50-317&318/97-08-01 VIO . Failure to establish test procedures for control element
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assembly position indication -
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.50-317&318/97-08-0 VIO Failure to meet technical specifications for two control
- element assembly position ind; cations out of service 50-317/98-001- LER Control Element Assembly Position Indication Out of Service l '50-318/98-001 LER Inoperable Emergency Diesel Generator 50-317/98-004 LER Battery Charger Breakers Missing Seismic Positioner 50-317&318/98-0 LER Missed Fire Watch Due to Personnel Error
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ATTACHMENT 2 Emergency Response Plan and Implementing Procedures Reviewed DOCUMENT DOCUMENT TITLE REVISIO N N ERP Calvert Cliffs Nuclear Power Plant Emergency Respor e Plan 26
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Calvert Cliffs EAL Basis Document 7 ERPIP Immediate Actions 21(Ch.1)
(Ch.1,3)
ERPIP 102 Superintendent-Nuclear Operations 4 ERPIP 103 On-Shift Operators O ERPIP 104 NRC Emergency Notification System (ENS) Communications 2 ERPIP 105 Control Room Communicator 4 (Ch.1)
ERPIP 106 Plant Parameters Communications-Control Room 1 ERFiP 107 Interim Radiological Assessment 4 ERPIP 109 Radiation Monitoring System (RMS) Communicator 2 ERPl? 201 Technical Support Director 4,5 ERPIP 202 Plant General Manager 3,4
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ERPIP 203 Chemistry Director 3 ERPIP 204 Operations Anelyst 1 ERPIP 205 Reactor Engineer 1 ERPIP 206 T3chnical Analyst 1 i
ERPIP 207 TSC Computer Maintenance Staff 3 ERPIP 208 Plant Parameters Communications-TSC 2 l
l ERPIP 209 Technical Support Center Communicator 4
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ERPlP 301 Operational Support Center (OSG) Director 5 l
! ERPIP 303 Radiation Protection Director 3 ERPIP 315 Plant Parameters Communications-OSC 1 ERP!P 401 Nuclear Engineering Facility (NEF) Director 5
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ATTACHMENT 2 (continued) I Emergency Response Plan and Implementing Procedures Reviewed l i
DOCUMENT DOCUMENT TITLE REVISIO !
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ERPIP 403 NEF/NSF Monitor 4,5 ,
ERPIP 502 Recovery Officer 2
. ERPl? 503 Emergency Operations Facility (EOF) Director 4 -
ERPIP 504 Environmental Assessment Director 1 (EC-1) ,
ERPIP 508 Plant Parameters Communications-EOF 2 ERPIP 509 Emerger,q Operations Facility Communicator 4 ERPIP 511 Radiological Assessment Director 3 l ERPIP 512 Radiological Assessment Specialist 2 ERPIP 760 Plant Parameters Communicatier.3-Media Centor 3 ERPIP 800 Core Damage Assessment '
ERPIP 801 Core Damage Assessment Using Containment Radiatien Dose 2 Rates ERPIP 802 Core Damage Assessment Using Core Exit Thermocouples 2
! ERPIP 8')3 Core Damage Assessment Using Hydrogen 2 i
ERPIP 804 Core Damage Assessment Using Radiological Ann'vsis of 2 j
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ERPIP 810 Main Steam System Radioactivity Release Es2 mate 2 (Ch.1)
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ERPIP 832 Emergency Work Permits 3 (EC-1)
i ERPIP 901 Communications Equipment 3 ERPIP 904 Emergency Response Training 4 ERPIP 905 Exercises, Tests and Drills 4 '
ERPlP Equipment Checklist 22
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