IR 05000317/1999005

Insp Repts 50-317/99-05 & 50-318/99-05 on 990509-0626.No Violations Noted.Major Areas Inspected:Plant Operations, Maint,Engineering & Plant Support

ML20209G216
Person / Time
Site:	Calvert Cliffs
Issue date:	07/13/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20209G212	List: IR 05000317/1999005 ML20209G208
References
50-317-99-05, 50-317-99-5, 50-318-99-05, 50-318-99-5, NUDOCS 9907190089
Download: ML20209G216 (13)

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U.S. NUCLEAR REGULATORY COMMISSION I

REGION 1 License Nos.: DPR-53; DPR-69 Docket Nos.: 50-317; 50-318

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Report Nos.: 50-317/99-05; 50-318/99-05 Licensee Baltimore Gas and Electric Company Post Office Box 1475 l Baltimore, Maryland 21203 Facility: Calvert Cliffs Nuclear Power Plant l UnRs 1 and 2 Location: Lusby, MD Dates: May 9,1999, to June 26,1999 l l

Inspectors: Scott Stewart, Senior Resident inspector Fred Bower, Resident inspector ;

Tim Hoeg, Resident inspector 1 Approved By: Michele G. Evans, Chief Projects Branch 1 1 Division or Reactor Projects i l

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9907190089 990713 PDR ADOCK 05000317 D PDR

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Executive Summary Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection Repot Nos. 50-317/99-05 and 50/318/99-05 This inspection report summarizes aspects of BGE operations, maintenance, engineering, and plant support. The report covers a seven-week period of resident inspectio Plant Operations The observed performance of the turbine building, auxiliary building, and outside operators was professional and thorough with the appropriate attention to detail, focus on safety, knowledge of equipment status, and observation of plant conditions. Communications between the operators and the control room were clear and concise. (01.2)

Maintenance Selected maintenance activities were performed safely and in accordance with BGE procedure The component cooling system was properly scoped and monitored in the BGE Maintenance Rule Program. The Unit 1 component cooling water system did not meet its system performance goals and an appropriate corrective action plan was implemented. (M1.1)

BGE appropriately monitored the performance and material condition of the containment spray system check valves and had estabiished Maintenance Rule system level performance goals commensurate with system safety and current industry operating experience. However, BGE's previous corrective actions were inadequate to prevent repetitive local leak rate test failures of discharge line check valves in both trains of the Unit 2 containment spray system. This was a non-cited violation of 10 CFR 50, Appendix B. (M2.1)

Enaineerina BGE engineering personnel appropriately directed the Unit 1 steam generator safety valve testing performed before reactor start-up and provided prompt ascessments of the test result l The testing was well controlled and completed without problems. (E1.1)

Plant SuDDort The Y2K upgrade of the Calvert Cliffs security computer system was well planned and effectively executed. (S1.1)

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. TABLE OF CONTENTS Executive S u m m ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

. TAB L E OF C O NTE NTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.2 Observation of Non-Licensed Plant Operators . . . . . . . . . . . . . . . . . . . 2 I I . M aintena n ce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 M1.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 M1.2 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 M2 Maintenance and Material Condition of Facilities and Equipment . . . . . . . . . . 5 l M2.1 Containment Spray Check Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 111. Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 j E1 Conduct of Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 '

E General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 IV. Plant S u pport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 S1 Conduct of Safeguards and Security Activities . . . . . . . . . . . . . . . . . . . . . . . . . 7 S Plant Security Computar Outage for Y2K Upgrade. . . . . . . . . . . . . . . . 7 V. M anagement Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 X2 Management Meeting Summary . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8  :

i ATTACHMENTS Attachment 1: Partial List of Persons Contacted l Inspection Procedures Used List of Acronyms Used  ;

Items Opened, Closed and Discussed

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ReDort Details Summary of Plant Status -

' On May 9,1999, Unit 1 was shutdown to Mode 5 for a planned outsge to perform a weld repair on a moisture separator reheater drain tank. Following the repair, Unit 1 was retumed to power on May 18 and operated at full power for the remainder of the inspection perio Unit 2 operated at full power for the duration of the inspection period following completion of the refueling outage on May 9,199 LODerations 01 Conduct of Operations

. O1.1 General Comments (71707)

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The inspectors performed daily reviews of plant operations during normal and back shift hours and observed that plant operations were conducted safely with a proper focus on nuclear safety. Control room operators were aware of plant conditions and conducted shift turnovers in a thorough manner. Communications were formal and in accordance with BGE policies. Control room equipment status was clearly identified. Procedures were properly used for plant operations. Shift supervision provided appropriate oversight of operations. With the completion of the Unit 2 refueling outage and a Unit 1 maintenance outage, many control room and system deficiencies had been corrected and outstanding deficiencies had m'.nimal impact on safe operations. Specific observations are detailed belo On May 9,1999, Unit i was shutdown for a planned maintenance outage to repair a small steam leak in a moisture separator reheater drain tank. Because the tank was not able to be isolated from the main condenser, a steam plant shutdown and the breaking of condenser vacuum were necessary for the repair.~ When the tank was inspected, a very small weld flaw (estimated 1/32 inch) and weld inclusion were identified. The flaw likely existed since fabrication of the tank during initial plant construction. The flaw was repaired and the tank retumed to compliance with American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section 8. The shutdown also facilitated repairs to a non-safety reactor vessel cavity cooling fan. The fan had failed in service and the redundant fan had provided cooling during the interim period. Following repairs and other minor work, the unit was restarted and retumed to power operation on

. May 18. No problems were identified by the inspectors during the outag The inspectors observed start-up activities in the Unit 1 control room on May 16 and 1 The start-up was conducted in accordance with procedures that covered pre-critical testing, the initial approach to criticality, and power escalation. The start-up operations were characterized by clear operator communications, operator peer checking, and effective oversight by shift supervision. The operators were observed using the appropriate procedures and data sheets. A senior reactor operator, a licensed operator, and a nuclear fuel management engineer were dedicated to support the start-up during the approach to criticality. The reactor operator manipulated the control rods in a

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deliberate and predicted manner. The reactor operator was attentive and responsive to changes in plant conditions as the start-up progressed. Good self-checking and independent oversight was noted during the manipulation of plant controls. The operators provided timely response to alarms and annunciators. The operators identified unexpected alarms and the appropriate use of alarm response procedures was note Around-the-clock support was provided by operations department management personnel. Operations management provided appropriate oversight of the startup activitie On May 18 during back shift hours, the inspector observed the Unit 1 control room operators respond to a 11B Reactor Coolant Pump Seal High Pressure Alarm. The operators responded to the alarm in accordance with the appropriate alarm response procedure. The operators identified the cause of the alarm as a failed first stage sea The operators immediately began monitoring the 11B seal pressures and temperatures as required by the alarm response procedure. There was no further degradation in the seal assembly and the unit was maintained at full power. As a contingency to the degraded condition, the operating crew reviewed and briefed the expeditious shut down procedure, in the event another seal were to significantly degrade or fail. The Unit 1 senior operator entered the failed pump seal condition into the BGE corrective action program. The inspector considered the operators' actions to be satisfactory and with proper focus on reactor plant safet .2 Observation of Non-Licensed Plant Operators Insoection Scope (71707)

The inspectors observed and assessed various non-licensed operators perfonning plant rounds and operator shift check Observations and Findings During back shift hours, the inspectors observed and assessed non-licensed nuclear plant operators (NPOs) performing tours and data collection in the turbine building, auxiliary building, and outside area watch stations. The inspectors verified that the NPOs attended the shift tumovers where equipment operating status, major work in progress, and plant issues were discussed. The inspectors observed that the NPOs participated in the shift crew tumover brief by presenting the equipment status of their respective watch station. Auxiliary building operators attended shift tumover wearing dosimetry in case they were immediately needed on the watch statio ,

The inspectors observed that the NPOs wore the necessary safety equipment and that they correctly followed all the posted waming and security signs. The operators were observed touring and collecting data from all assigned areas including the main turbine generator, vital switchgear rooms, cable spreading room, vital battery rooms, service water heat exchanger room, the auxiliary feed water room, emergency diesel generator rooms, intake structure, fire pump house, and other areas. The NPOs verified plant parameters were in compliance with applicable technical specifications and checked to l

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verify that log readings were within the specified ranges. The NPOs were observed I correctly checking that the associated equipment was in the proper lineup and l functianing satisfactorily. The operators also assessed fire protection and personnel l

safety in the various areas. Communications between the operators and the control room were formal and complete, using three-way communications. The operators were observed practicing good self- checking techniques throughout the tours. Minor discrepancies were corrected on-the-spot, noted to re-inspect during second rounds, and/or documented in issue reports (irs). No unacceptable out of specification readings were noted by the plant operators or the inspecto Conclusions The observed performance of the turbine building, auxiliary building, and outside nuclear plant operators was professional and thorough v.ith the appropriate attention to detail, focus on safety, knowledge of equipment status, and observation of plant condition Communications between the operators and the control room were prope . Maintenance 1 M1 Conduct of Maintenance M1.1 General Comments Inspection Scope (62707)

The inspectors reviewed maintenance activities and focused on the status of work that involved systems and components important to safety. Component failures or system problems that affected systems included in tl BGE Maintenance Rule Program were assessed to determine if the maintenance was, effective. Also, the inspectors directly observed all or portions of the following Maintenance Order (MO) work activities:

MO 1199804190 12B SW/SRW Heat Exchanger Cleaning MO 1199900405 Replacement of 11 Cavity Cooling Fan Motor ,

MO 1199901768 12 Component Cooling Pump Seal Replacement  !

MO 1199804172 Remove and Inspect 1 A EDG 1 A1 Air Compressor Shuttle Valve l

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MO 2199902230 Calibrate 21 SG Feedwater Flow Instrument Observations and Findinas  !

During the maintenance activities, the inspectors observed that technicians were experienced and knowledgeable of their assigned duties. Maintenance personnel ,

J practiced peer checking and self-verification while doing work. The pre-job briefings included the important aspects of each maintenance task and were effective in ensuring the work was conducted in accordance with BGE requirements. Supervisory oversight j was appropriat l I

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On May 14, the inspector observed maintenance personnel disassembling the No.12 component cooling pump to replace a failed mechanical seal. The inspector verified the pump was properly isolated and that the tag-out was administratively correct. The inspectors observed that the maintenance workers used effective peer checking techniques and complied with the approved BGE maintenance order (M01199901768).

The work was completed the following day and the pump returned to servic The inspector reviewed the Maintenance Rule scoping document with the component cooling water system manager, The inspector also discussed the seal failure with the system manager. The subject seal failure was the fourth functional failure for the system and exceeded a Maintenance Rule goal of three failures or less every two years. This goal was outlined in the component cooling system scoping document. The system was appropriately designated in an a(1) status. Engineering and maintenance personnel were reviewing the recent failures. BGE had completed a corrective action plan (performance goal setting) to retum the component cooling water system to a(2) status, but intended to re-examine the plan in light of the recent seal failure. The inspectors found the Maintenance Rule application to be appropriat On a component level, the No.12 component cooling pump performance goal of less than 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> of unavailability per every two years was met, including the recent seal replacement. A total of 232 hours0.00269 days <br />0.0644 hours <br />3.835979e-4 weeks <br />8.8276e-5 months <br /> has been documented from June 18,1997, to dat Conclusions Selected maintenance activities were performed safely and in accordance with BGE procedures. The component cooling system was properly scoped and monitored in the BGE Maintenance Rule Program. The Unit 1 component cooling water system did not meet its system performance goals and an appropriate corrective action plan was implemente M1.2 Routine Surveillance Observations 1 Inspection Scope (61726) '

The inspectors observed all or portions of the following surveillance test procedures (STPs):

l STP-O-73K-2 Containment Spray Pump Operability Test STP-O-73K-1 Containment Spray Pump Operability Test STP-O-73J-2 LPSI Pump Operability Test STP-O-731-1 HPSI Pump and Check Valve Quarterly Test .

STP-O-5A-1 .AFW System Quarterly Surveillance Test STP-O-5A-2 AFW System Quarterly Surveillance Test i

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5 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 a pre-test briefing followed by a quastion and answer session attended by all test participants. The test participants were knowledgeable of the testing and their assigned responsibilitie Supervisory and engineering personnel participation was observed in the conduct of the surveillance tests. Minor test discrepancies were docurr ented in the BGE corrective action program and correcte 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 M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Containment Spray Check Valves inspection Scope (62707)

The inspectors reviewed the repetitive failure of Unit 2 containment spray check valves 2CKVSI-330 and 2CKVSI-340. The inspectors also reviewed the actions taken in accordance with the BGE Maintenance Rule Program and assessed the implementation of the program's corrective action and goal setting processe Observations and Findinos The containment spray system consists of two trains that have separate penetrations through the containment structure. One check valve located inside containment and one i check valve located outside containment provide containment isolation for each header j of the containment spay syste I On March 22,1999, during the Unit 2 refueling outage, BGE performed local leak rate testing (LLRT) on the penetrations for both trains of the containment spray system in accordance with 10 CFR 50, Appendix J. BGE was unable to pressurize the inside i containment discharge line check valves, 2CKVSI-330 and 2CKVSI-340, for both traine i of the containment spray syste !

BGE initiated troubleshooting and inspection of these check valves. A service representative from the valve manufacturer was contracted to provide onsite technical support. In each case, the valve disk was found " sticking" and not fully contacting its seat. The disk could be fully seated with minor physical force or mechanical agitatio The manufacturer's representative determined that this condition occurred because the valves' internal alignment tolerances and clearance had not been maintained during

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maintenance activities following previous problems. The inspector was informed that the prior maintenance activities replaced or machined parts and lapped the valve seat As an initial corrective action, & cause analysis was performed by the engineering staff that indicated that the disks most likely misaligned with the seats during initial forward-flow testing conducted during plant start-up activities. Since the flow testing was performed after the LLRT procedure was completed, the potential leak path was present

, for the entire Unit 2 operating cycl BGE's other corrective actions included restoring the valve intamal alignment tolerances and clearances to the manufacturer's specifications. The vendor technical manual was revised to include the additional alignment instructions and specifications. Multiple low flow and LLRT tests were performed to verify that the valves viere retumed to an operable condition. _ Some of these tests were performed with a transparent Lexan cover on the valves to visually verify that the disk fully seated and did not stic The inspectors noted that the Maintenance Rule baseline program inspection (reference Inspection Reports 50-317 & 50-318/98-04 and the associated violation 50-317&318/98-04-01) had previously identified that the containment spray system had not been properly changed from (a)2 status to (a)1 status, based on a series of repetitive failures of 2CKVSI-330 in 1995 and 1997. As a result, check valve 2CKVSI-330 was changed to (a)1 status and entered into the corrective action system by BGE, as documented in IR3-004-529, dated May 28,1998. The inspectors reviewed BGE's response to the 1999 containment spray LLRT failures and found that check valve 2CKVSI-330 remained in (a)1 status and that action was taken to change check valve 2CKVSI-340 to (a)1 status, as documented in IR3-004-842, dated May 28,199 The BGE check valve component engineer presented the "(a)1 - Evaluation, Corrective Action and Goal Setting Plan," to the Maintenance Rule Expert Panel on June 17,199 The inspectors reviewed the pan and observed that it was self-critical, concise, and complete. The causes of the two functional failures were identified as: (1) insufficient past corrective actions; (2) insufficient procedural and technical manual support; and, (3)

prior maintenance induced failures.' Proposed corrective actions included upgrading maintenance and test procedures. Subsequent discussions with plant engineering personnel identified that both 2CKVSI-330 and 2CKVSI-340 were planned for replacemen BGE continued the performance goal to have zero functional failures of the containment spray check valves,1/2CKVSI-330 and 1/2CKVSI-340. The component engineer also documented the review of industry operating experience for the containment spray check valves. The inspectors concluded that BGE had appropriately monitored the performance and condition of the containment spray check valves. The inspectors also concluded that BGE had established Maintenance Rule system level goals commensurate with safety and had taken into account industry operating experienc BGE's review of the LLRT history for 2CKVSI-330 and 2CKVSI-340 indicated that these valves had failed seven of nine and six of nine of the last local leak rate tests,

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respectively. Consequently, BGE's previous corrective actions were inadequate to I preclude repetitive LLRT failures of discharge line check valves in both trains of the Unit 2 containment spray system. This inadequate corrective action was a violation of 10 CFR Part 50, Appendix B, Criterion XIV, Corrective Action. BGE risk assessment personnelinformed the inspectors that the contribution of this event to containment release was low, because the two additional check valves in each containment spray train remained operable. The NRC Region i Senior Reactor Analyst review and agreed with 'his risk assessment. This Severity Level IV violation is being treated as a Non-Cited Violation, (NCV 50-317&318/99-05-01), consistent with Appendix C of the NRC Enforcement Policy. This violation is in the BGE corrective action program as IR3-024- )

842 and IR3-015-54 l fanclusions BGE appropriately monitored the performance and material condition of the containment i spray system check valves and had established Maintenance Rule system level performance goals commensurate with system safety and current industry operating experience. However, BGE's previous corrective actions were inadequate to prevent repetitive local leak rate test failures of discharge line check valves in both trains of the Unit 2 containment spray system. This was a non-cited violation of 10 CFR 50, Appendix Ill. Engineering E1 Conduct of Engineering E1.1 General Comments On May 16, the inspectors observed Unit 1 steam generator safety valve testing being performed prior to reactor start-up. The testing was controlled by BGE engineering with maintenance, operations, and contracted support. The inspector verified that the safety lift set point data of the safety valves were within technical specifications surveillance requirements. BGE enD ineering personnel were observed directing the testing and performing on-the-spot assessment of the test results. The testing was well controlled {

and completed without problem l IV. Plant SuDDort l

S1 Conduct of Safeguards and Security Activities  ;

S1.1 Plant Security Computer Outage for Y2K Upgrade On the evening of June 16,1999, the Calvert Cliffs security computer system was l

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upgraded to Y2K ready. During the upgrado process, various security alarms and indications were temporarily out of service. The BGE security staff took compensatory measures and effectively maintained access control to and from the plant and vital areas while completing the Y2K upgrade. BGE effectively planned and executed the security 4 l

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1 system outage including reviewing applicable lessons leamed from the industry and I performing a pre-evolution brief of affected staff prior to the evolutio V. Mananoment Meetings X1 Exit Meeting Summary j At the conclusion of the inspection, on June 28,1999, the inspectors presented the inspection results to Mr. Carroll and others of BGE management. The BGE representatives acknowledged the findings presented.

l X2 Management Meeting Summary j i

On June 16,1999, Mr. A. Randolph Blough, Region 1 Director of the Division of Reactor Projects toured the Calvert Cliffs site and met with BGE managers and staff. The discussions included recent site activities and general plant performance observation On June 21,1999, NRC Commissioner Nils Diaz toured the Calvert Cliffs site and j met with BGE managers and staff. The discussions included a review of recent site activities and were general in nature. Commissioner Diaz was accompanied by a member of his staff. Mr. Wayne Lanning, Director of the Division of Reactor Safety,

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represented Region 1 during the visi On June 21 through June 24,1999, two inspectors from the NRC Spent Fuel Project Office conducted an inspection of the programs for the Calvert Cliffs Independent Spent Fuel Storage Installation and met with BGE managers and staff. The results of this inspection will be documented in a separate inspection report.

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ATTACHMENT 1 Partial List of BGE Persons Contacted 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 Protection Manager C. Earls, General Supervisor, Chemistry A. Edwards, Supervisor, Security K. Nietmann, Manager Nuclear Assessment Manager D. Hiebel, Project Management Department Manager B. Doroshuk, Life Cycle Project Manager INSPECTION PROCEDURES USED lP 71707- Plant Operations IP 62707 Maintenance Observation IP 61726 Surveillance Observation IP 37551 Onsite Engineering IP 71750 Plant Support Activities 1 LIST OF ACRONYMS USED I

AFW- Auxiliary Feedwater Pump j ASME American Society of Mechanical Engineers i BG Baltimore Gas and Electric Company i DRP Division of Reactor Projects !

ED Emergency Diesel Generator HPSI High Pressure Safety injection IR issue Report LLRT . Local Leak Rate Testing i

LPSI Low Pressure Safety injection

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l- NCV Non-Cited Violation NPO, Nuclear Plant Operator PDR- Public Document Room SRO Senkt Reactor Operator l l

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ITEMS OPENED. CLOSED. AND DISCUSSED

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50-317&318/99-05-01 NCV Inadequate corrective actions for repetitive failure of the '

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Unit 2 containment spray isolation check valves

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