IR 05000317/1999003
| ML20196E046 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/16/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20196E042 | List: |
| References | |
| 50-317-99-03, 50-317-99-3, 50-318-99-03, 50-318-99-3, NUDOCS 9906280025 | |
| Download: ML20196E046 (35) | |
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l U.S. NUCLEAR REGULATORY COMMISSION Region 1 License Nos.: DPR-53; DPR-69 Docket Nos.: 50-317;50-318 Report Nos.: 50-317/99-03;50-318/99-03 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, MD
Dates: March 21,1999 to May 8,1999 Inspectors: J. Scott Stewart, Senior Resident inspector Tim L. Hoeg, Resident inspector Ron Nimitz, Senior Health Physicist, Region l William Cook, Project Enginee'r, Region i Approved By: Michele G. Evans, Chief Projects Branch 1 i Division of Reactor Projects I
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i 9906290025 990616 PDR ADOCK 05000317 G PDR
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l Executive Summary Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection Report Nos. 50-317/99-03 and 50-318/99-03 This integrated inspection report summarizes aspects of BGE operations, maintenance, engineering, and plant support. The report covers a seven week period of resident inspection, the results of a specialist inspection of the Calvert Cliffs radiation protection program, and a programmatic review by a Region I specialist of the Calvert Cliffs Year 2000 (Y2K) computer system preparation Plant Operatio_ng The core offload and refueling of Unit 2 were done adequately. The inspectors observed good communications and extensive engineering support. A number of material deficiencies with fuel
' handling equipment were identified prior to and during fuel handling. Many of the problems were corrected prior to fuel movement; however, some problems persisted and required
. operator workaround. BGE had initiated a long term project to upgrade fuel handling control systems. (01.2) '
BGE identified that a safety tagout had been hung which potentially degraded the cooling water
. availability for the 1B emergency diesel generator and other safety components. An engineering i evaluation completed after discovery of the problem showed that affected safety equipment remained operable in part, because of the low temperature of the Chesapeake Bay while the tagout was in effect.- When the problem was found, BGE took corrective action. The issue was
. a non-cited : Solation. (01.3)
Maintenance BGE responded appropriately to problems identified during a failed overspeed trip test of the 22 auxiliary feedwater pump turbine. A troubleshooting plan was implemented eventually identifying and resolving a rotor imbalance problem. (M1.2)
The December 22,19971B emergency diesel generator (EDG) surveillance test failure was significant because the EDG was determined to have been unavailable for 12 days prior to discovery and redundant train equipment had been removed from service at various times during this period, contrary to Technical Specifications. However, because the EDG failure was viewed as not reasonably avoidable, the NRC exercised enforcement discretion for this Technical Specification violation. When the cause of the 1B EDG failure was determined, BGE failed to report this condition to the NRC in a timely manner. This was a non-cited violatio (M8.1) ]
i Engineering ;
During a BGE audit of their fuels vendor, a potential concem with the integrity of a fuel assembly !
was identified. The issue was entered into the BGE corrective action program and an inspection was conducted to resolve the matter. The inspectors found the BGE actions to be appropriat ~(E1.1) ;
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, -. l Executive Summary (cont'd)
Plant Support BGE implemented improved and effective radiological controls for the Unit 2 outage. BGE was maintaining personnel radiation exposures as low as is reasonably achievable and well within applicable limits. (R1.1)
BGE augmented its radiological controls organization to support outage activities and implemented its Radiation Protection improvement and Outage Plans. (R1.2)
Training and qualification of contracted radiological control technicians was commensurate with assigned duties. Radiation workers were provided appropriate radiological controls trainin (RS)
BGE was implementing enhanced oversight of radiological work activities to verify and validate the effectiveness of its radiation protection program improvement efforts. (R7)
BGE was providing conservative estimates of personnel neutron exposure using staytime calculations and personnel monitoring devices. BGE was reviewing its neutron survey and monitoring practices forimprovement. (R8)
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TABLE OF CONTENTS Executive S ummary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
- Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..... 1 l . Ope ration s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 O1 Conduct of 0perations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.2 Unit 2 Fuel Handling Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.3 Saltwater Air Tagout Problem . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 II. Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... .... ..... .5 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . ... .. .......5 M1.1 General Comments . . . . . . . . . . . . . . . . . . . . . ...............5 1 M1.2 22 Auxiliary Feedwater Pump Terry Turbine Maintenance . . . . . ... 6 l M1.3 Routine Surveillance Observations . . . . . . . . . . . ...... .. . .. 7 M8 Miscellaneous Maintenance Iscues . . . . . . . . . . . . . . . . . . . . . . . . . .. 7 M8.1 (Closed) LER 50-317/97-010, Action Time Exceeded Due to Failed Diesel Generator Governor . . . . . .... . .......... ...... 7 M8.2 (Closed) Violation 50-317&318/98-02-01: Failure to store a diesel generator governor in accordance with vendor recommendation . 10 lli .~ Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... . .......... .. ... 10 E1 Conduct of Engineering . . . . . . . .... .. .. . . .. . . ...... 10 E Problem Identified During Fuel Vendor Audit . . . . . .... . . . . . . 10 IV. Plant Support . . . . . . . . . . ............ ...................... .......... 11 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . 11 ,
R1.1 Applied Radiological Controls for the Unit 2 Outage . . . . . . . . . . . . . 11 l R1.2 Radiation Protection Program and Organizational Changes . . . . . . . 13 R5 Staff Training and Qualification in RP&C Activities . . . . . . . . . . . . .. . . . . . . 13 l R7 Quality Assurance in RP&C Activities . . . . . . . . . . . . . . . .. . . . . . . . . . . . . 14 '
R8 Miscellaneous RP&C lssues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 R8.1 (Closed) Inspector Followup Item (IFI) 50-317&318/98-12-06:
Neutron Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 X2 Management Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 X3 Review of Year 2000 Program and Implementation . . . . . . . . . . . . . . . . . . . . 17 iv
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l Table of Contents (cont'd)
ATTACHMENTS l
.. Attachment 1: Partial List of Persons Contacted I Inspection Procedures Used List of Acronyms Used items Opened, Closed and Discussed j
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Attachment 2: Slides from NRC License Renewal Inspection 99-02, Scoping and Screening i
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Report Details Summary of Plant Status With the exception of minor power changes for scheduled maintenance and testing, Unit i remained at full power. Unit 2 was shutdown for a scheduled refueling and maintenance outage until May 6, when the reactor was made critical. Through the rest of the inspection period, Unit 2 power was incrementally increased as testing was complete l. ODerations 01 Conduct of Operations 01.1 General Comments (71707)
Plant operations were conducted safely with a proper focus on nuclear safety. The inspectors conducted daily reviews of ongoing plant operations and observed that the conduct of operators was professional and safety conscious. Reactor operators were aware of plant conditions and equipment status. Shift turnovers included a complete review of plant status. BGE performed risk assessments prior to maintenance and core damage risk was minimized by sequencing of work. Supervisory oversight of operations was appropriat On April 26, Unit 2 was in the reduced inventory condition for reactor cociant pump seal replacement and to remove steam generator nozzle dams. The inspectors observed that BGE maintained two redundant trains of emergency makeup capability to be used if problems with decay heat removal occurred. Plant electrical power was stable with no switchyard work allowed during the reduced inventory period. Emergency diesel generators were available. Operators were aware of the reduced inventory condition and announcements were made using the site announcing system to ensure heightened awareness of other plant personnel. On April 27, the work requiring reduced inventory was completed and the condition was exited with no problem .2 Unit 2 Fuel Handling Operations Insoection Scope (71707)
The inspectors observed fuel handling operations during the core offload and refueling of Unit 2. Also, the inspectors reviewed the fuel handling records and discussed these operations with engineering and operations personnel, Observations and Findings Prior to the Unit 2 refueling outage, the inspectors observed that BGE had taken efforts to ensure safe fuel handling operations by completing a number of preventive and corrective maintenance tasks on the fuel handling equipment. After the reactor was shutdown on March 12, additional preventive work was done including various oil changes, general inspections, and setpoint checks. Also, prior to fuel handling, a number of preventive pre-operational checks were completed such as verifying system alignments, position indication checks, hoist checks, and weighing system calibration , .. 1
The inspectors observed some of .his work in progress or verified that these tasks were i complete l During these preventive maintenance activities, prior to fuel handling, BGE identified alignment problems with the refueling machine hoist box. The hoist box had been removed and refurbished prior to the outage; however, some problems persisted. BGE removed the box, realigned internal components and reinstalled the hoist box. Following
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the re-installatiors a number of other components on the fuel handling machine were identified as ha/rq alignment problems. Attempts to return all components to full alignment were partially successful, but some minor misalignments were unable to be corrected. Also, testing by BGE identified that the main hoist brake was problematic and this brake was replaced. BGE identified that spurious hoist overloads sometimes necurred during withdrawal of the refuel equipment and an engineering evaluation of these overloads was provided to the operators. BGE personnel told the inspectors that none of these outstanding issues could affect tne safe handling of fue l Because of the outstanding deficiencies and the extent of recurring problems, on March 31, prior to fuel offload from the reactor, BGE operations, engineering, and maintenance personnel developed a formal protocol for ensuring that fuel handling ;
operations were safe. The protocol specified a definition of safe conditions for fuel movements, established a chain of management oversight for ensuring safety during fuel movement, and defined a list of contacts should problems devele Core offload was started on April 1 and completed without significant delay. During the offload, BGE noted changes in alignment of the fuel handling equipment, spurious hoist overloads were noted on the refueling machine, and a fuel transfer proximity switch l failed. Engineering personnel developed a temporary alteration that compensated for l the failed fuel transfer proximity switch. The misalignments and spurious hoist overloads !
were evaluated by engineering and operations personnel, determined to not affect safety, and were left uncorrected while the fuel was moved. A BGE operations supervisor told the inspectors that these items were considered as operator workaround On April 1, the inspector observed the Unit 2 reactor core being offloaded into the spent fuel pool. The inspector observed proper use of the fuel handling procedures. Foreign material exclusion (FME) precautions were taken to prevent inadvertent foreign material introduction into core components. The precautions including removal or tethering of loose materiat prior to allowing the material or personnel to enter into fuel handling areas. Constant and formal communications between fuel handling personnel at the spent fuel pool, in containment, and in the control room were observed. The fuel movements were completed without problem The inspectors observed that nuclear fuels and plant systems engineers were present at the fuel handling bridge and in the control room during the fuel handling. The engineering duties included monitoring activities while fuel was being moved and providing support when problems were encountered. The inspector verified technical specification requirements for containment integrity, ventilation alignments, and nuclear
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instrumentation were met. Also, the inspectors reviewed Updated Final Safety Analysis Report (UFSAR) Sections 9.7, Fuel and Reactor Component Handling Equipment; 14.18, Fuel Handling incident; and 15.9, Refueling Operations. No deviations from the UFSAR descriptions were identifie The inspectors noted that BGE had initiated a bng term project to replace the refueling machine and upgrade fuel handling control systems. Also, the existence of numerous and varied problems with fuel handling equipment had been documented in the BGE corrective action syste Conclusion The core offload and refueling of Unit 2 were done adequately. The inspectors observed good communications and extensive engineering support. A number of material deficiencies with fuel handling equipment were identified prior to and during fuel handling.- Many of the problems were corrected prior to fuel movement, however, some problems persisted and required operator workaround. BGE had initiated a long term project to upgrade fuel handling control system .3 Saltwater Air Tagout Problem Inspection Scope The inspectors reviewed a tagout hung on the Unit 2 saltwater air system and the effects of the tagout on emergency diesel generator operabilit Findinos and Observations
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On March 31, BGE determined that on March 19, a tagout had been hung which isolated saltwater air normally supplied as a backup air supply to the service water control valves for the 2A emergency diesel generator (EDG). The tagout was hung in anticipation of work on the saltwater air system, however, the actual work (air system check valve replacement) was not scheduled to be performed until the Unit 2 reactor was defuele In the defueled condition, the 2A emergency diesel would no longer be needed should offsite power be los l At the time of the tagout, the 2A EDG cooling water was supplied from the Unit 1 service water system, as allowed by Technical Specification Amendment Number 205, provided ;
by NRC letter to BGE, dated Mar'ch 8,1999. The result of the tagout was that if a loss of j offsite electrical power occurred on Unit 1, concurrent with a loss of instrument air on !
Unit 2, some cooling water for the 1B emergency diesel and other Unit 1 service water ,
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loads would have been diverted to the 2A diesel engine degrading the cooling water supply for Unit 1 components should a design basis event occur. This scenario did not occur and was considered b) ihe inspectors to be of low likelihoo i On April 5,1999, BGE completed an engineering evaluation of the tagout problem and ;
determined that because the Chesapeake Bay temperature was below 50 degrees j
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1 Fahrenheit, the 2A EDG and all service water loads associated with the 12 service water l system would have adequately performed their design function Calvert Cliffs Technical Specification 5.4.1 stated that written procedures be implemented covering the applicable procedures in Appendix A to NRC Regulatory Guide 1.33, Revision 2, dated February 1978. The regulatory guide appendix included administrative procedures for equipment control including safety tagging. BGE implemented this requirement in Calvert Cliffs Administrative Procedure, NO-1-112, Safety Tagging. The safety tagging procedure, in step 4.10, stated that the shift manager was responsible to ensure that tagouts were appropriate for plant conditions and that any tagout that unnecessarily degraded plant safety or reliability should not be approved. Contrary to the above, Safety Tagout 2199800744 was approved on March 19,1999, and unnecessarily degraded the service water cooling availability for Unit 1 systems by isolating the flow path for saltwater air to the 2A EDG service water control valves. Operations contingency plans and watchrtation turnover sheets during the tagout period identified that 21 saltwater air compressor was to be maintained operable (for EDG 2A), while 2A EDG cooling was supplied from Unit This BGE identified Severity Level IV violation is being treated as a Non-Cited Violation, i consistent with Appendix C of the NRC Enforcement Policy. This violation is in the BGE corrective action program as issue Report IR3-037-512. (NCV 50-317&318/98-03-01)
When BGE identified the problem, the 1B EDG was declared inoperable and Technical Specification Action 3.8.1.8 was initiated. Because no work had been done on the air system, within one hour, the tagout was removed and the 1B EDG was returned to operable status. Further, BGE operations did a review of the problem and identified a number of failed barriers and contributing factors. Corrective actions were taken that focused on these barriers and factors. These actions included caution tagging of special system lineups in place during the Unit 2 outage and other operability verification c. Conclusions BGE identified that a safety tagout had been hung which potentially degraded the cooling water availability for the 1B emergency diesel generator and other safety cornponent An engineering evaluation completed after discovery of the problem showed that affected safety equipment remained operable in part, because of the low temperature of the Chesapeake Bay while the tagout was in effect. When the problem was found, BGE took corrective action. The issue was a non-cited violatio , . I
5 11. Maintenance M1 Conduct of Maintenance
. M1.1 General Comments Insoection Scope (62707)
. The inspectors reviewed maintenance activities and focused on the status of work that j involved systems and components important to safety. Component failures that affected j systems included in the BGE maintenance rule program were assessed to determine if the maintenance was effective. Also, the inspectors directly observed all or portions of the following work activities:
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MO2199702740 Replace Safety injection Tank Check-Valves L MO2199104967 Repair Containment 10 Foot Level Perimeter Expansion Joint MO2199605553 22 ECCS Room Cooler Cleaning MO2199704657 Sludge Lancing of the 22 Steam Generator Tube Bundles MO2199801841 . Replace 22 LPSI Pump Check Valve Observations and Findings During the maintenance activities, the inspectors observed that technicians were experienced and knowledgeable of their assigned duties. Maintenance personnel practiced peer checking and self-verification while doing work. Pre-job briefings included the important aspects of each maintenance task and appeared effective in ensuring the j work was conducted in accordance with BGE requirements. Good radiation control practices were observed during the maintenance planning and performanc Supervisory oversight was appropriat !
Unit 2 fuel handling equipment had been designated a(1) under the maintenance rule (10 CFR 50.65). BGE had established four goals as part of the a(1) corrective action plan. Three of these goals were met: complete the outage with no repost upender failures, complete a satisfactory visualinspection of upender welds, and core alterations with no loss of positive control of a fuel assembly. The fourth goal that was not met was fuel handling equipment availability greater than 80 percent during the time period !
specified for fuel movement in the outage plan. Problems with the equipment caused delays that prevented BGE from meeting the goal (See O1.2). BGE entered this missed goal in their corrective action program and intended to develop a new corrective action plan for presentation to the maintenance rule expert panel. Also, BGE had started a ,
Collective Significance Analysis for management review of all fuel handling concem I BGE engineering personnel informed the inspectors that additional corrective actions
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General maintenance observations and implementation of the maintenance rule were acceptabl )
M1.2 22 Auxiliary Feedwater Pump Terry Turbine Maintenance Inspection Scope (62707)
The inspector observed troubleshooting and maintenance being performed on the 22 steam driven auxiliary feedwater (AFW) pump turbine. The work included governor removal, gear box removal, journal / thrust bearing removal, turbine casing removal, and various clearance measurement Observations and Findinas On April 7,1999, during a planned overspeed trip test, BGE personnel detected an abnormal noise coming from the governor end of 22 AFW pump turbine. The test was stopped and troubleshooting started using BGE procedures. On April 9, the inspector observed that troubleshooting documentation was being used and that the troubleshooting instruction was clear and focused on the reported abnormal nois During the troubleshooting, the inspector observed maintenance personnel spin the turbine to approximately 1000 rpm without the gear box or governor assembly installe No abnormal noise was noted. This evolution was well controlled with good engineering suppor On April 12,1999, the AFW turbine was reassembled and operated using auxiliary steam. The abnormal noise was once again detected. BGE developed a second plan to further investigate the problem. On April 14, the inspector observed BGE maintenance workers remove and inspect the inboard and outboard journal bearings. The irispector observed that the bearings were normal. BGE management oversight was present during the troubleshooting including system engineer, system manager, maintenance }
supervisor, and an engineering supervisor. The turbine was reassembled and made ready for retes On April 15, the turbine was again tested unsatisfactorily. At higher speed, the turbine bearing temperatures increased to the point where the control room followed instructions and tripped the turbine remotely. On April 16, a contingency plan was put in place and disassembly of the turbine performed for further inspection. No unusual wear or out of !
specification readings were noted during this inspection of the turbine bearings, casing, and wear rings. The rotor assembly was sent to a vendor for inspection and balancin ,
Vendor data indicated that a significant imbalance was being seen at the rotor. The i vendor rebuilt and balanced the rotor to original specifications. BGE performed a root !
cause review of the turbine conditions and concluded that the most probable cause of the noise was a resonance at certain speeds caused from the imbalance within the rotor i and coupling assembly. On April 26, the 22 AFW Pump turbine was reassembled with I
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the newly rebuilt rotor and the turbine ran at full speed with no unusual noise or vibration note Conclusions BGE responded appropriately to problems identified during a failed overspeed test of the 22 auxiliary feedwater pump turbine. A troubleshooting plan was implemented eventually identifying and resolving a rotor imbalance proble M1.3 Routine Surveillance Observations inspection Scope (61726)
The inspectors observed all or portions of the following surveillance tests:
STP-O-55A Containment Closure Verification ETP-98-001 Component System Cooling Check Valve Replacement Test ETP-98-011 LPSI System Check Valve Replacement Test STP-O-4B-2 Emergency Safeguard Features Actuation Test Observations and Findinos The inspectors found that the selected surveillance activities were performed safely and in accordance with approved procedures. Test details were discussed at pre-test i briefings attended by all test participants. During testing, the inspectors observed that test participants were knowledgeable of their responsibilities. Supervisory and engineering personnel participation was observed in the conduct of the surveillance tests. Minor test discrepancies were documented in the BGE corrective action program and resolve Conclusions Surveillance testing was thorough and consistent with industry standards. The inspectors observed that minor discrepancies noted during the tests were properly entered into the corrective action syste M8 Miscellaneous Maintenance issues M8.1 (Closed) LER 50-317/97-010, Action Time Exceeded Due to Failed Diesel Generator Governor i inspection Scope l
A licensee event report (LER) was closed during an onsite inspectio , .
b. Findinas and Observations The LER described the failure of the 18 emergency diesel generator during a surveillance test on December 22,1997. The failure occurred when the diesel failed to start because a small sliver of stainless steel had lodged inside the governor shutdown solenoid. BGE stated in the LER that the stainless steel sliver was most likely introduced into the governor oil system during maintenance in November 1997, when copper tubing was replaced with stainless steel tubing. The sliver probably lodged in the shutdown solenoid following a successful surveillance test on December 10,1997. The problem with the 1B engine was not discovered until the next surveillance test on December 22, 1997. BGE estimated that the diesel was out-of-service for approximately 338 hours0.00391 days <br />0.0939 hours <br />5.588624e-4 weeks <br />1.28609e-4 months <br /> until the problem was discovered and correcte The BGE analysis stated that the event had no actual safety consequence because the reactor plant operated normally during the out-of-service time. BGE evaluated the potential consequence of having the redundant emergency diesel generator and various safety equipment unavailable during the 338 hour0.00391 days <br />0.0939 hours <br />5.588624e-4 weeks <br />1.28609e-4 months <br /> period and identified time periods when safety margins were degraded. Because of these various safety system unavailabilities, BGE stated that the potential safety consequences would have been significant had a design basis accident occurred concurrent with a loss of offsite powe The licensee identified that the non-safety related station blackout diesel generator was available during this 338-hour interval to mitigate the potential consequence of a loss of normal and emergency electric power concurrent with a design basis accident. The LER was reviewed by an NRC Senior Reactor Analyst with similar conclusions on significanc The inspectors reviewed the work package that was used when the stainless steel tubing was installed in November 1997. The work instruction specified foreign material precautions in accordance with Calvert Cliffs procedure MN-1-109, Foreign Material i
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Exclusion. The foreign material exclusion practices included deburring the ends of the stainless steel tubing, an air flush to remove debris, and other routine quality assurance handling and cleanliness controls. While these practices were reasonable and universally applied to safety relatod work activities, in this instance, they were insufficient to prevent introduction of the stainless steel sliver into the diesel engine governor control system. The diesel successfully passed an operability test after the maintenance on !
November 19,1997, and another routine surveillance test on December 10,1997. BGE l surmised that the engine became inoperable when the sliver caused the solenoid l plunger to bind when actuated to shutdown the diesel following the December 10 !
surveillance test. The 1B EDG was determined to be inoperable an estimated 338 hours0.00391 days <br />0.0939 hours <br />5.588624e-4 weeks <br />1.28609e-4 months <br />, well in excess of the 72-hour allowed outage time specified in (former) Technical Specification 3.8.1.1, Action b. The problem also resulted in the plant being in a condition outside of the design basis because redundant equipment was at times, out of service during the inoperable perio This Severity Level 111 violation of Unit 1 Technical Specifications was considered for escalated enforcement in accordance with the NRC Enforcement Policy. The following factors were considered: the governor piping replacement was done in accordance with
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maintenance instructions that specified reasonable cleanliness controls; these cleanliness controls were included in the pre-job briefing of the workers; these controls were implemented in accordance with standard BGE quality assurance measures with management oversight; and the diesel generator successfully passed the post-maintenance testing and a subsequent routine surveillance test on November 19 and December 10,1997, respectively. Because of these factors, the NRC staff viewed the failure of the 1B EDG as not reasonably avoidable. Therefore, in accordance with Section Vll.B.6 of the NRC Enforcement Policy, the NRC is exercising enforcement discretion to not cite the violation of Technical Specification 3.8.1.1. (NCV 50-317&318/99-03-02)
BGE was slow to determine the cause of the December 1997 governor failure. This observation was previously discussed in NRC Inspection Report 50-317&318/98-02, Section M2.2. BGE told the inspectors that the selection and qualification of a vendor to perform the failure analysis contributed to this delay. The governor was evaluated by a vendor on May 14,1998, and a report was provided to BGE on June 15,1998. The vendor report was reviewed by the inspectors, as part of this inspection, and it coniirmed that the failure was due to a stainless steel contaminant. The report stated that stainless steel was not used in governor component assembly. Following the discovery of the contaminant, the vendor completely disassembled the governor to inspect for further contamination and none was foun The inspector verified that no other governor failures attributed to stainless steel foreign material had occurred at Calvert Cliffs, although a foreign material failure due to wear of a nylon fitting had occurred on the 1B engine subsequent to this December 1997 even BGE found these two events unrelated. A third governor failure in March 1998 resulted, in part, from problems with governor storage in the Calvert Cliffs warehouse. This occurrence was the subject of a previous NRC violation (VIO 50-317&318/98-02-01).
BGE stated in LER 50-317/97-10 that recommendations to further reduce the potential for foreign material contamination of diesel governor systems have been added to applicable procedures and instruction The inspectors determined that the vendor's failure analysis was received by BGE in June 1998, but the event was not reported to the NRC until January 1999. This event was reported under two criteria: 10 CFR 50.73(a)(2)(i)(B), a condition prohibited by the plant's Technical Specifications; and 10 CFR 50.73(a)(2)(ii), a condition that resulted in the nuclear plant being outside the design basis of the plant.10 CFR 50.73(a) req'uires that these events be reported within 30 days of discovery. However, the inspectors ,
identified that approximately six months had elapsed since BGE became aware that the !
1B EDG had been inoperable between its successful operation on December 10,1997 l and the December 22,1997 failure to start. This 10 CFR 50.73 reporting violation was !
neither willful nor repetitive and restoration of compliance was not applicable. This -
Severity Level IV violation was treated as a Non-Cited Violation consistent with j Appendix C of the NRC Enforcement Policy. This violation was in the BGE corrective !
action program as IR3-020-513. (NCV 50-317&318/99-03-03)
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10 Conclusions i
The December 22,199971B emergency diesel generator (EDG) surveillance test failure was significant because the EDG was determined to have been unavailable for 12 days j prior to discovery and redundant train equipment had been removed from service at i various times during this period, contrary to Technical Specifications. However, because I the EDG failure was viewed as not reasonably avoidable, the NRC exercised enforcement discretion for this Technical Specification violation. When the cause of the
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1B EDG failure was determined, BGE failed to report this condition to the NRC in a timely manner. This was a non-cited violatio M8.2 (Closed) Violation 50-317&318/98-02-01: Failure to store a diesel generator governor in accordance with vendor recommendation The violation involved the storage of a diesel engine governor for long periods of time {
without lubrication oil. When the governor was placed in service, it failed to operate, contributing to BGE exceeding a technical specification limiting condition of operation time. BGE responded to the Notice of Violation in a letter dated June 15,1998. The ,
inspectors reviewed the corrective actions in the response to the notice and found them i to be appropriate. The inspectors discussed the violation with BGE personnel and found that storage of emergency diesel generator governors was currently being conducted using an in-storage preventive maintenance instruction that had been initiated for diesel and similar governora. The inspectors considered the BGE corrective actions to be satisfactory and the violation was close lil. Enaineerina l
E1 Conduct of Engineering
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E Problem identified During Fuel Vendor Audit Inspection Scope The inspectors observed the BGE response to a finding resulting from a BGE audit of the fuel vendo Findinos and Observations On March 31,1999, BGE identified that one new fuel assembly being stored in the spent fuel pool could potentially have one loose rod in the upper most spacer grid. The problem was identified during a BGE sponsored audit at the fuel vendor facility and entered in the Calvert Cliffs corrective action program. The auditor determined by discovery of incomplete documentation, that fuel assembly 2R223 could have a loose rod in the upper most spacer grid. The fuel vendor later determined that the fuel assembly had been reworked but the post-work inspection had not been documente l
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On April 5,1999, BGE fuels engineering personnel with assistance from a fuel vendor l representative performed an inspection of the fuel assembly for proper seating of the fuel pin in the spacer grid. The NRC inspectors observed the inspection. The spacer grid clearance was measured by both the vendor and a BGE fuels engineer, then documented. The inspection confirmed proper seating of the fuel rod. Throughout the inspection, good radiological controls were observed. The response of BGE to the problem was appropriate, including entering the condition in their corrective action program and performing an inspection. BGE engineering was effective in bringing the issue to closure prior to placing the fuel in the Unit 2 reacto Conclusions During a BGE audit of their fuels vendor, a potential concern with the integrity of a fuel assembly was identified. The issue was entered into the BGE corrective action program and an inspection was conducted to resolve the matter. The inspectors found the BGE actions to be appropriat IV. Plant Sypoort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Applied Radiological Controls for the Unit 2 Outage Inspection Scope (83750)
The inspector selectively reviewed the implementation and adequacy of radiological controls for Unit 2 outage work activities. Areas reviewed included planning and preparation for work, external and internal exposure controls, and radioactive material and contamination controls. The inspector reviewed radiological controls for BGE l defined high and medium risk work activities including reactor vessel inspection work i and steam generator maintenance and inspection activities. The inspector reviewed )
activities during day shift and back shift, attended shift tumover and outage meetings, l and attended worker briefing meeting The reviews were against requirements contained in applicable regulations and station procedure l Observations and Findinos BGE performed effective planning and preparation for outage radiological work activitie The work was categorized from a risk perspective and planned accordingly. Potential risk significant contingent work was also planned consistent with radiological ris Overall ALARA efforts were good. BGE met its 1998 site ALARA goals and had established reasonable ALARA goals for the outage. Numerous efforts were made to reduce personnel occupational exposure for work activities to as low as is reasonably achievable. Significant ALARA efforts and worker briefings were incorporated into the
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outage schedule and ALARA planning effectively considered lessons learned. Of particular note was the effective implementation of the chemistry program to capture and remove crud from the primary coolant system during reactor shut down for refuelin BGE appropriately monitored and controlled access to areas of the station that could exhibit elevated radiation levels during implementation of the shutdown chemistry program. Video cameras were extensively used to remotely monitor areas of elevated ambient radiation level Personnel dosimetry was properly issued and worn and radiation protection personnel performed multiple checks of personnel dosimetry use prior to allowing workers entry into areas of elevated radiation levels. Multiple dosimeters were used when appropriat No individuals were observed loitering in elevated radiation area Radiation work permits were improved to provide clearer guidance for workers and were properly implemented by the workers. The permits presented expected radiological conditions and supported worker briefings. Calibrated and checked survey instrumentation was used for pre-work and ongoing radiological surveys. Engineering controls were effectively used to minimize airborne radioactivity. Widespread use was made of lapel air samplers to monitor the breathing zone of workers. Selocted workers, wearing respiratory protective equipment, were verified to have received training, fit testing, and medical certification to wear the equipmen Access points to areas of elevated radiation levels or art . s exhibiting contamination were properly posted and barricaded. Appropriate acs ,4 controls were implemented for High Radiation Areas including those areas meetirQ 0;iteria to be locked. Overall, radioactive material was properly labeled and posted as appropriate. Personnel performed contamination monitoring after exiting contaminated areas. There was effective overall oversight of work activities by radiation protection personnel and work supervisor BGE properly implemented its radiation work permit program. Job coverage records were implemented and radiation survey records indicated that appropriate radiological surveys were performed. BGE conservatively suspended work if questions or concerns were noted by personne As of the date of this inspection, there were no significant internal or external personnel radiation exposures. Radiation exposures were well within applicable limits. BGE properly evaluated low levelintakes of radioactive materials and used scaling factors, as appropriate, to estimate intakes of hard to detect radionuclides, c. Conclusions BGE implemented improved and effective applied radiological controls for the Unit 2 outage. BGE was maintaining personnel radiation exposures as low as is reasonably achievable and well within applicable limit .-
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' R1.2- Radiation Protection Program and Organizational Changes Inspection Scooe (83750)-
- The inspector reviewed selected program and organizational changes since the previous inspection. The implementation of the Radiation Protection Improvement Plan was selectively reviewed. The inspector reviewed work in progress, reviewed applicable documentation, and interviewed cognizant personne ' b. - Observations and Findinas A defined radiation protection organization was established for the outage. BGE also enhanced its radiation protection organization through addition of several permanent radiation protection professionals. Of particular note was the establishment of a Radiation Protection Outage Plan, which provided responsibilities and authorities of f ey organization member BGE continued to implement its Radiation Protection improvement Plan. BGE revised and implemented numerous radiation program procedures to provide for enhanced controls of radiological work activities for the outage. Examples included job coverage in radiologically controlled areas, ALARA planning and special work permit (SWP)
preparation, area posting and barricading, radioactive material controls, and air samplin BGE was aware of recent changes in Department of Transportation shipping regulations (effective April 1, iggg) ano had changed applicable station procedures and trained applicable personnel relative to these matter ' Conclusions BGE augmented its radiological controls organization to support outage activities and implemented its Radiation Protection improvement and Outage Plan R5 Staff Training and Qualification in RP&C Activities a. - Inspection Scope (83750)
The inspector selectively reviewed the training and qualification of contracted radiological control technicians hired to augment the staff for the current outage. The inspector selected individuals for review who were providing oversight of high and medium risk radiological work activities and reviewed applicable qualification record The review was against applicable regulatory and licensee procedure requirement o e' 4-14 Observations and Findinas Contracted radiological control technicians were provided training and qualification
- ' consistent with their assignments. Personnel selection was conducted in accordance with technical specification requirements and past experience was evaluated to meet applicable Technical specification experience requirements. Radiation protection l technicians, performing oversight of radiological work activities, were knowledgeable of l potential hazards of ongoing work activities and with minor exceptions monitored and
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- controlled work, from a radiological controls perspective, appropriatel j
' Radiation workers were provided radiological controls training and briefings consistent
' with the risk significance of their work activities. Workers attended initial extensive briefings of planned radiological risk significant work and also received supplemental ongoing job periodic briefing Conclusions j Training and qualification of contracted radiological control technicians was commensurate with assigned duties. Radiation workers were provided appropriate radiological controls trainin ,
i R7 Quality Assurance in RP&C Activities 1 Inspection Scope (83750L ]
The inspector evaluated the effectiveness of BGE's self-identification and corrective action processes. The evaluation included a selective review of issue report and outage !
oversight effort The inspector evaluated performance via observation of work activities, tours of the RCA, discussions with cognizant personnel, review of applicable documentation, and review and evaluation of applicable station procedure Observations and Findinas- r Radiation protection related lasue Reports were initiated at low thresholds. The issues were elevated to management, evaluated, and reasonable corrective actions were implemented based on the radiological risk significance of the issu BGE was effectively implementing its Radiation Protection Improvement Plan. BGE developed and implemented an outage assessment plan to assess the effectiveness of the improvement Plan. The plan included criteria for assessment of administrative processes, pre-job briefings, field observations, radiation supervisor observations,
' training effectiveness, routine activity reviews, and foreign material exclusio ' The effectiveness reviews consisted of 24-hour oversight of outage activities by assessors assigned to each shift. The assessors consolidated findings and presented
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them to management. A special radiological controls outage display board was posted at various locations to inform personnel of positive and negative finding The quality assurance group had also developed and was implementing an outage assessment pla Conclusions BGE was implementing enhanced oversight of radiological work activities to verify and validate the effectiveness of its radiation protection program improvement effort R8 Miscellaneous RP&C issues R8.1 (Closed) Inspector Followup item (IFI) 50-317&318/98-12-06: Neutron Monitoring Inspection Scoce (83750)
The inspector selectively reviewed BGE's program for personnel neutron monitorin The inspector reviewed calibration of survey instrumentation, personnel monitoring devices, and personnel exposure result Observations and Findinas BGE provides surveys and monitoring of neutrons for personnel entering the reactor containment with the reactor at power. Personnel neutron dosimeters supplied are accredited consistent with 10 CFR 20.1501. Radiation survey meters are used to ;
measure neutron exposure rates and neutron exposures are controlled via stay time j calculations consistent with general guidance contained in NRC Regulatory Guide 8.14, Personnel Neutron Dosimeters, Revision 1. Neutron exposure results (based on calculations of exposure rate and time) are logged and the results are updated after processing of personnel neutron monitoring devices and receipt and review of result BGE was providing calibration of a dedicated neutron survey meter at the National Institute of Standards and Technology (NIST) with a source approximating a fission type spectrum. This instrument was then used, in accordance with a station approved procedure and guidance contained in ANSI-N323, Radiation Protection Instrument Calibration,1978 (reaffirmed 1993), as a transfer instrument (i.e., secondary standard) to establish calibration factors for a neutron calibration source maintained at the statio The source was used to calibrate and source check other neutron meters used during entries into containmen BGE's technical procedure used calibration guidance contained in ANSI N323A, Radiation Protection instrumentation, Test and Calibration, Portable Survey Instruments, 1997. The survey meters were source checked daily and inspected prior to use for entry into containment. During the entries, BGE noted that both the survey meter and personnel monitoring devices provided conservative personnel exposure results, in they both over estimated personnel exposure at lower neutron energy levels (e.g., less than
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about 10 Kev). Notwithstanding, the meter provided dose results, using stay time calculations, less than that measured by the personnel monitoring devices. To preclude inadvertent exceeding of administrative SWP dose limits, BGE implemented an instrument reading correction factor to account for the lower instrument response (relative to the personnel monitoring device) resulting from the low energy neutrons encountered in containment. The need to perform a follow-up review on the adequacy of this factor was identified as an inspector follow-up item during a previous NRC inspectio l The estimated neutron doses, based on stay time calculations, were 2% lower than those measured by the personnel monitoring devices in 1997, and about 9% higher in 1998 after application of the factor. Personnel neutron exposure results for 1997 and 1998 indicated neutron deep dose equivalents of less than 5% of the total station l effective dose equivalent. No individual exceeded 600 millirem total neutron dose for 1997 or 199 No violations or significant concerns were identified. The use of the factor appeared reasonable and BGE was reviewing the adequacy and use of the factor. BGE issued several corrective action issue reports to provide for review and evaluation of neutron survey and monitoring practices including energy response of the survey meter and personnel monitoring devices. The inspector follow item is close c. Conclusions BGE was providing conservative estimates of personnel neutron exposure using staytime calculations and personnel monitoring devices. BGE was reviewing its neutron survey and monitoring practices for improvemen V. Manaaement Meetinos X1 Exit Meeting Summary At the conclusion of the inspection, on May 17,1999, the inspectors presented the inspection results to Mr. Katz and others of BGE management. BGE acknowledged the findings presented. Preliminary exit meetings for the radiological controls inspection and the review of Year 2000 computer readiness were conducted on April 9 and April 23, respectivel X2 Management Meeting Summary An inspection of the BGE license renewal efforts was done during the week of February 8,1999. This inspection was documented in NRC Inspection Report 50-317&318/99-02, dated March 26,1999. A meeting with the public, where the NRC summarized the results of this inspection, was held at the Calvert Cliffs Education Center on April 15,1999. The slides used by NRC personnel at this meeting is included as Attachment 2 to this inspection repor r
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X3 Review of Year 2000 Program and implementation A review was conducted of Calvert Cliff's Year 2000 (Y2K) activities using NRC Temporary Instruction (TI) 2515/141, " Review of Year 2000 (Y2K) Readiness of Computer Systems at Nuclear Power Plants." The review included aspects of BGE Y2K management planning, assessment, documentation, and remediation activities. BGE Y2K testing and validation, notification activities, and contingency plans were also reviewed. The NRC reviewers used NEl/NUSMG 97-07, " Nuclear Utility Year 2000 Readiness," and NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning," as the primary references for this review. The detailed results of this review will be combined with similar reviews of Y2K programs at other U.S. commercial nuclear power plants and summarized in a report to be issued by the NRC staff by July 31,199 l l
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I ATTACHMENT 1 Partial List of Persons Contacted DftE C. Cruse, Vice President, Nuclear Energy Division P. Katz, Plant General Manager K. Cellars, Manager, Nuclear Engineering L. Wechbaugh, Superintendent, Nuclear Maintenance M. Navin, Superintendent, Nuclear Operations B. Montgomery, Director, Nuclear Regulatory Matters
- S. Sanders, General Supervisor, Radiation Protection T. Sydnor, General Supervisor, Plant Engineering D. Holm, General Supervisor, Plant Operations T. Pritchett, Superintendent, Technical Support L. Smialek, Radiation Protec' ion Manager C. Earls, General Supervisor, Chemistry INSPECTION PROCEDURES USED l
IP 71707 Plant Operations j IP 62707 Maintenance Observation IP 61726 Surveillance Observation
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IP 37551 Onsite Engineering j IP 71750 Plant Support Activities IP 83750 Radiation Protection Tl 2515/141 Review of Year 2000 Readiness of Computer Systems at Nuclear Power Plants LIST OF ACRONYMS USED IR Calvert Cliffs issue Report LER Licensee Event Report i PDR Public Document Room ALARA As Low as is Reasonably Achievable IFl NRC Inspector Follow-up item RP&C Radiological Protection & Chemistry Contrc?
SWP Special(Radiation) Work Permit ,
NCV Non-Cited Violation FME Foreign Material Exclusion i UFSAR Updated Final Safety Analysis Report l EDG Emergency Diesel Generator NIST National Institute of Standards and Technology AFW Auxiliary Feedwater VIO Violation
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ITEMS OPENED. CLOSED. AND DISCUSSED Opened / Closed I
. 50-317&318/99-03-01 ' NCV Failure to follow safety tagging procedure to ensure that tagouts were appropriate for plant conditions l
j 50-317&318/99-03-02 NCV Emergency diesel generator out-of-service for greater than the allowed technical specification action time (Enforcement discretion exercised per Section Vll.B.6 of NRC Enforcement Policy)
i 50-317&318/99-03-03 NCV Failure to report a condition prohibited by the technical I specifications and outside the design basis within 30 days !
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after discovery Closed
- 50-317/97-010 'LER Action Time Exceeded Due to Failed Diesel Generator
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Governor
50-317&318/98-12-06 IFl Review Neutron Survey meter correction factor &318/98-02-01 VIO Failure to store a diesel generator governor in accordance with vendor recommendations
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