IR 05000317/1999006
| ML20212A349 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/08/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20212A204 | List: |
| References | |
| 50-317-99-06, 50-318-99-06, NUDOCS 9909160159 | |
| Download: ML20212A349 (26) | |
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U.S. NUCLEAR REGULATORY COMMISSION Region 1 License Nos.: DPR-53; DPR-69 Docket Nos.: 50-317; 50-318 Report Nos.: 50-317/99-06; 50-318/99-06 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 l
Dates: June 27,1999 to August 14,1999 Inspectors: J. Scott Stewart, Senior Resident inspector Fred L. Bower, Resident inspector Tim L. Hoeg, Resident inspector William Maier, Emergency Preparedness Spec.ialist Kenneth S. Kolaczyk, Reactor Engineer Julian Williams, Engineering Specialist Paul R. Frechette, Security Specialist Approved By: Michele G. Evans, Chief Projects Branch 1 Division or Reactor Projects 9909160159 99090s PDR ADOCK 05000317 !
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I Executive Summary Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection Repot Nos. 50-317/99-06 and 50/318/99-06 This integrated inspection report summarizes aspects of BGE operations, maintenance, engineering and plant support. The report covers a seven week period of resident inspection and the results of specialist inspections of security, emergency preparedness procedures, and I
maintenance rule corrective action Plant Operations ?
Unit 1 automatically shutdown following the failure of a main output transformer during harsh weather. Plant systems and operators responded appropriately and the reactor was quickly stabilized in hot shutdown. Following transformer repair and testing, the unit was re-started and the electrical system retumed to full power without complications. (Section 01.2)
During the reactor startup, in addition to the four assigned operators, the inspector observed a j number of unnecessary individuals, including three trainees and an engineer in the Operator-at-the-Controls area during a feedwater malfunction and transient. Although there were no actual consequences, the large number of individuals in the vicinity of the controls was considered a performance deficiency where clear communication between the operators and supervisory oversight of the reactor could have been challenged. BGE took action to minimize the number of individuals allowed to enter the control area. (Section 01.3) l l
Maintenance Maintenance to change the oil for the 1 A emergency diesel generator bearing resulted in oil ,
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contaminating the generator housing and being sprayed in the diesel room when the engine was started. The cause of the contamination and spray was an inadvertent overfill of the generator oil cavity. At the time of the occurrence, the oil overfill was not documented in the maintenance work order. The failure to document actions taken outside the scope of the work order was a non-cited violation. (Section M1.2)
Engineering BGE conducted testing of used nuclear fuel assemblies to confirm that the fuel remained within its design. Unexpected oxide layer thickness ar.d some evidence of blistering were observe The vendor was informed and further inspection was conducted. BGE started an engineering evaluation to assure that reactor fuel remained within its design limits. (Section E1.1)
BGE identified that control room ventilation in-leakage exceeded design values. The design calculations were later revised and submitted to NRC for review. The inspectors did not agree with BGE that increased control room air inleakage was not a condition outside of the plant design basis since the operability assessment relied on assumptions and coefficients that were not described in the Calvert Cliffs FSAR. After the inspector's inquiry, BGE reported the issues in accordance with 10 CFR 50.72 and 10 CFR 50.73. Failure to make a timely report was a non-cited violation. (Section E8.1)
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Executive Summary (cont'd)
Plant Support BGE was conducting security and safeguards activities in a manner that protected public health and safety in the areas of access authorization, alarm stations, communications, and protected area access control of personnel, packages and vehicles. This portion of the program, as implemented, met BGE's commitments and NRC requirements. (Section S1)
Security facilities and equipment in the areas of protected area assessment aids, protected area detection aids, and personnel search equipment were determined to be well maintained and were able to meet BGE's commitments and NRC requirements. (Section S2)
Security and safeguards procedures and documentation were being properly implemente Event logs were being properly maintained and effectively used to analyze, track, and resolve j safeguards events. (Section S3) i The nuclear security officers (NSOs) adequately demonstrated that they had the requisite knowledge necessary to effectively implement the duties and responsibilities associated with their position. Security force personnel were being trained in accordance with the requirements .
of the BGE Training and Qualification Plan. Training documentation was properly maintained j and accurate, and response capabilities were being exercised. (Section S4, SS) !
The level of security management support was adequate to ensure effective implementation of i I
the program, and was evidenced by adequate staffing levels and the allocation of resources to support programmatic needs. (Section S6)
The review of BGE's security audit program indicated that the audits were comprehensive in scope and depth, that the audit findings were reported to the appropriate level of management, l and that the program was being properly administered. In addition, a review of the documentation applicable to the self-assessment program indicated that the program was being effectively implemented to identify and resolve potential weaknesses. (Section S7)
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TABLE OF CONTENTS Executive Sum mary . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . ...................ii TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...................iv ,
i Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
.01 Cond uct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.2 Unit 1 Automatic Reactor Shutdown . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.3 Reactor Trip Recovery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3 11. M aintena nce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 i M Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 M1.1 General Comments . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 M1.2 Emergency Diesel Generator Maintenance . . . . . . . . . . . . . . . . . . . . 5 1 M1.3 Routine Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 i M8 . Miscellaneous Maintenance Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 M8.1 (Closed) Violation 50-317 & 318/98-04-01 . . . . . . . . . . . . . . . . . . . . 8 M8.2 (Closed) Violation 50-317 & 318/98-04-02 . . . . . . . . . . . . . . . . . . . . 8 M8.3 (Closed) Violation 50-317 & 318/98-04-03 . . . . . ............... 8 M8.4 (Closed) Violation 50-317 & 318/98-04-04 . . . .. . . . ............ 8 Ill . Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 E1 Conduct of Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 E Nuclear Fuel Design Verification . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 E2' Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . 10 E2.1 Maintenance Rule Expert Panel Meeting ... . .............10 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 E (Closed) Unresolved item 50-317/318(98-80-01) . . . . . . . . . . . . . . . . 10 IV. Plant S upport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . 12 P3 EP Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . . . . . . 13 S2 Status of Security Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . 14 S3 Security and Safeguards Procedures and Documentation . . . . . . . . . . . . . . . 15 S4 Security and Safeguards Staff Knowledge and Performance. . . . . . . . . . . . . 15 S5 Security and Safeguards Staff Training and Qualifications. . . . . . . . . . . . . . . 16 S6 Security Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 S7 Quality Assurance (QA) in Security and Safeguards Activities . . . . . . . . . . . . 17 V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . ............... 18 IV l
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Table of Contents (cont'd)
ATTACHMENTS
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Attachment 1: Partial List of Persons Contacted Inspection Procedures Used '
Items Opened, Closed and Discussed List of Acronyms Used
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Report Details Summary of Plant Status Unit 1 operated at full power until July 24, when the reactor automatically shutdown on loss of load following a main turbine generator trip. The reactor remained in hot shutdown until August 2. Unit 1 was reconnected to the grid on August 3 and returned to full power on August Unit 2 remained at full power throughout the inspection period except for minor power reductions for main turbine valve testing and main condenser waterbox cleanin I. 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 daily tours of the control room to observe the conduct of activities and verify safety system alignments. Equipment deficiencies were discussed with shift supervision allowing the inspectors to evaluate equipment conditions and to monitor changes in riant risk. Control room operators were aware of plant status and
- maintenan'.e activities. Communications were observed to be formal and in accordance with BGE expectations. Significant activities were preceded by detailed briefings of involved personne .2 Unit 1 Automatic Reactor Shutdown i Insoection Scooe
[ The inspectors reviewed the circumstances of an automatic reactor shutdown of Unit Observations and Findinas On July 24, at 2:38 p.m Unit 1 automatically shutdown (tripped) from 100 percent powe The shutdown occurred following a main transformer fault protection actuation which tripped the main turbine causing an automatic reactor trip due to loss of load. The transformer fault protection system had responded to the failure of a main generator output transformer (U-25000-12) during harsh weathe l All control rods fully inserted and all safety equipment operated as designed during and ,
following the automatic shutdown. Plant operators stabilized the reactor in Mode 3 (Hot i Shutdown) and normal post-trip activities were started. These activities included evaluation of the transient, confirmation of fuelintegrity, and recovery planning. A BGE l Significant issues Findings Team was assembled to determine the cause of the trip and I recommend any corrective action l l
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BGE properly notified the NRC of the trip in accordanc6 with 10 CFR 50.72. The inspectors responded to the site to observe the post-trip activities. Later, the inspectors reviewed the BGE post-trip review and found no discrepancie On July 30, the Significant issues Findings Team reported to the Calvert Cliffs Plant Operational Safety Review Committee (POSRC) their assessment of the plant trip. The team determined that the main transformer had experienced a 500kV phase to ground short circuit during harsh weather. Plant response to the main transformer ground, which included the main transformer fault protection isolation and the main turbine and reactor trip, was as expected. The exact cause of the transformer ground was indeterminate. Heavy rain and lightening were in progress at the time of the failure and BGE postulated a scenario which involved lightening and a low resistance path to ground for the transformer "A" phase. The inspectors noted visible damage to the U-25000-12 transformer bushing in the form of black bum marks and perforations with similar findings on the normally grounded fire deluge nozzles and the transformer casing in the vicinity of the bushing. These observations supported that the "A" phase short circuited to ground, initiating the transien BGE performed extensive testing of the transformer and electrical generation systems following the trip. The "A" phase bushing on the main transformer was replaced. festing was completed to assure that the repaired transformer was operational prior to plant restart. The retum of the electrical system to full power operation was completed on August 4 without complication Q.gr)clusions Unit 1 automatically shutdown following the failure of a main output transformer during harsh weather. Plant systems and operators responded appropriately and the reactor was quickly stabilized in hot shutdown. Following transformer repair and testing, the unit was re-started and the electrical system retumed to full power without complication O1.3 Reactor Trio Recovery Inspection Scooe The inspectors observed portions of the recovery of Unit 1 from hot shutdown to full powe Observations and Findinas On August 2, as electrical system repairs and testing were being completed, the reactor was taken critical and Unit 1 was retumed to power operation. The inspectors observed the reactor restart and power escalation. BGE reactor engineering personnel were observed in the control room making confirmatory observations of the reactor restar Criticality was achieved within the estimated critical condition limits; however, engineering personnel intended to review the startup to identify the reason for the critical condition being nearer the higher limi .
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During power escalation, at approximately 11 percent power, a control problem was experienced with the 11 feedwater regulating valve bypass valve and manual action was promptly taken to establish control of steam generator level in accordance with Calvert Cliffs Abnormal Operating Procedure AOP-3G," Malfunction of the Main Feedwater System." The inspector was in the control room at the time of the feedwater transient and the following observations were made: l
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Ten individuals entered or were in the Operator-at-the-Controls area near the feedwater station during the abnormal operating procedure (AOP) implementation, including the dedicated turbine operator (RO), dedicated reactor operator (RO), dedicated feedwater operator (RO), dedicated primary plant Senior Reactor Operator (SRO), a feedwater system engineer, three trainees observing the power escalation, the Control Room Supervisor (SRO), and the Shift Manager (SRO). The Control Room Operator (RO) and another trainee were in the operating area, but outside of the Operator-at-the-Controls area during the transien .- At least momentarily, all of the individuals in the operator-at-the-controls area L re observed looking at the feedwater station and the adjacent steam generator leves indications. None of the operators, including the dedicated reactor SRO and RO, were observed monitoring the primary plant for changes in reactivity or other problems that may have occurred (but did not) in conjunction with the feedwater transient and the Control Room Supervisor did not direct that the primary plant be monitored. The reactor operator later stated that plant power and thermal parameters were on the control room display and that any changes would have been detecte Although the above observations did not contribute to or result in any aggravation of the feedwater transient, the inspector was concemed that overall reactor oversight and management of the control room environment could have been challenged while performing the abnormal operating procedure. Specifically, the large number of individuals that had entered the feedwater control area potentially interfered with clear communication between the reactor operators and the shift supervision and may have allowed the control room operators to become momentarily distracted from their overall responsibilities. The inspector considered that the presence of ten individuals, including three trainees and an engineer in the Operator-at-the-Controls area of the feedwater station, was different than the training operators receive on abnormal operating procedure implementation, and was a human performance deficienc The inspector discussed the observations with operations supervision. Following the observation, operations management held a critique of the abnormal operations with the i operating crew and took action to ensure that operators remained focused on reactivity and other plant conditions. BGE stated that having the trainees in the Operator-at-the-Controls area, without clear assignments during conduct of the abnormal operating procedure was not an expected behavior. BGE operations supervision established a policy for the number of individuals in the control area and stated that further review would be conducted to determine appropriate controls for trainees and other non- '
essential personnel in the control roo :
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Subsequently, action was initiated to diagnose and restore proper automatic control of the feedwater control system. On August 3, following transformer testing and repairs, the main generator was tied to the electrical grid and power was increased without complicatio c.- Conclusions During the reactor startup, in addition to the four assigned operators, the inspector observed a number of unnecessary individuals, including three trainees and an engineer in the Operator-at-the-Controls area during a feedwater malfunction and transien Although there were no actual consequences, the large number of individuals in the l vicinity of the controls was considered a performance deficiency where clear communication between the operators and supervisory oversight of the reactor could have been challenged. BGE took action to minimize the number of individuals allowed to enter the control are . Maintenance l 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 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:
MO2199900799 21 Component Cooling Outlet Temperature Loop Calibration MO2199804114 21 Component Cooling Heat Exchanger Cleaning MO2199803406 22 Charging Pump Valve Replacement MO2199801418 22 Charging Pump Packing Replacement MO1199900129 12 Component Cooling Heat Exchanger Tube Cleaning MO2199802999 22 Auxiliary Feedwater Control Valve Diaphragm Replacement MO1199902960 11 A Service Water Heat Exchanger Cleaning MO2199801058 Replace Reactor Protection Channel D Power Supply Observations and Findinas Cleaning of the 11 A saltwater / service water heat exchanger was emergent work in response to increased saltwater differential pressure and decreased flow through the heat exchanger. The inspectors noted that the cleaning was performed to ensure the accident cooling function of the heat exchanger. The inspector verified that the saltwater and service water systems were properly included within the scope of the maintenance rule program as risk significant systems. The inspectors reviewed the maintenance rule
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functions identified for the saltwater and service water systems and concluded that appropriate performance criteria had been specified. The Unit 1 service water system was classified as an (a)(1) system and goals had been established. BGE also had a plan for retuming the system to (a)(2). The inspectors noted that BGE appropriately considered risk and administratively verified that the 12 train of service water was operable prior to removing the 11 A heat exchanger from servic The Unit 2 reactor protection system channel "D" power supply for thermal margin low pressure protection was replaced safely and effectively. A quality verification inspector was observed providing oversight of the power supply replacement. The reactor protection system had been classified as maintenance rule (a)(1) and power supplies were identified for maintenance rule repetitive functional failures. BGE initiated a performance monitoring program for power supplies. The Unit 2 reactor protection system channel"D" power supply was replaced as a preventive measure because the BGE performance monitoring program identified degrading performance based of the power supply. The inspectors also noted that BGE appropriately considered risk and verified that the three other reactor protection system channels were operable prior to removing channel "D" from servic During maintenance on the 22 charging pump, the inspectors noted that the technicians exhibited safe work practices and appeared knowledgeable and experienced. The radiation safety technicians provided good job coverage and support. The inspectors noted that although the technicians completed the procedure as written, the repair procedures seemed to be used in a " referral use" manner while a " continuous use" manner was specified. The inspectors discussed the observation with a technician and a first line supervisor. The BGE personnel stated that they understood the inspectors'
observation and that a review of the work would be completed to determine if any changes were appropriate. The inspector concluded that the discrepancy was minor and no additional concems were identified. The charging pump maintenance was completed without problem Conclusions During the selected 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. Minor discrepancies were corrected by BG M1.2 Emeroency Diesel Generator Maintenance Inspection Scope The inspectors observed and reviewed preventive maintenance on the 1 A emergency diesel generator syste .
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b. Observations and Findinas On July 27 and 28, planned preventive maintenance was performed on the air-cooled 1 A emergency diesel generator. One of the approximately 30 tasks was to replace the lubrication oil for the generator bearings. In accordance with maintenance order, MO1199901453, the used oil was drained then the oil cavity was refilled from an oil tank using a hand pump. A sight glass mounted on the bearing housing was monitored by the technicians for the correct amount of oil. The inspectors were later informed that the technicians inadvertently overfilled the cavity and exceeded the maximum level on the sight glass. In response to overfilling, the mechanic drained oil from the housing until the level appeared normal, completing the job. When the engine was started for the post-maintenance test, oil was sprayed in the vicinity of the bearing by a shaft mounted fan on the generator bearing. The engine run was stopped, an issue report was written, (IR3-035-979) and cleanup of the sprayed oil was starte '
Review of the problem identified that the generator bearing oil sump had intema!
connections to both the adjacent fan and the generator housing. The presence of the intemal connections was unknown to the maintenance workers during the oil chang The fan unit was dismantled and approximately two quarts of oil from the bearing cavity were found to have entered the fan cavity through the intemal port. Additionally, the generator housing cover was removed and about two ounces of oil were found in the 4 generator _ housing. The oil was collected and cleaned from the fan cavity, generator housing, and the areas around the engine and generator where spray had occurre Additional issue reports cddressing the oil overfill and some preliminary corrective actions were written (IR3-035-857. IR3-035-858). The generator was inspected by BGE electrical maintenance personnel to verify that no oil had contaminated the generator windings (IR3-018-665).
The inspectors discussed the oil overfill occurrence with maintenance and engineering personnel and reviewed the maintenance order. Although engineering personnel had been informed of the oil overfill at the time of occurrence, the overfill and re-drain were not fully evaluated nor documented in the maintenance order. The inspectors were concemed with the failure to evaluate and document the overfill at the time because of the potential that a maintenance error could go undetected during the post-maintenance test and that a degraded diesel could be placed into servic Calvert Cliffs Technical Specification 5.4.1 required that the written procedures specified by NRC Regulatory Guide 1.33, Revision 2, Appendix A, be implemented. The regulatory guide, in Appendix A, Section 9.3, required General Procedures for the Control of Maintenance. BGE implemented this requirement, in part, in Calvert Cliffs Procedure, MN-1-100 " Conduct of Maintenance", which stated in step 5.4.D, that additional steps (those not listed in the maintenance order) may be taken during completion of maintenance as long as the additional activities are within the skill of the craft and are documented in the " Action Taken" section of the maintenance orde Contrary to this requirement, on July 28, the draining of the 1 A emergency diesel generator oil sump after the overfill was an additional activity that was not documented in the " Action Taken" section of Maintenance Order MO1199901453. The inspector
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considered that the actions taken to drain the oil to the correct level would normally be i within the skill of the maintenance craft. The failure to follow Step 5.4.D of MN-1-100, was a violation of NRC requirements. This Severity Level IV violation was treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the BGE corrective action system as IR3-028-445. (NCV 50-337&338/99-06-01)
Following the oil cleanup and inspections, the engine was restarted and later successfully passed a post-maintenance operational test. BGE told the inspectors that they intended to complete an overall assessment of the quality of maintenance activities associated with the 1 A emergency diesel generator system (IR3-004-610). Conclusions Maintenance to change the oil for the 1 A emergency diesel generator bearing resulted in oil contaminating the generator housing and being sprayed in the diesel room when the engine was started. The cause of the contamination and spray was an inadvertent overfill of the generator oil cavity. At the time of occurrence, the oil overfill was not documented in the maintenance work order. The failure to document actions taken outside the scope of the work order was a non-cited violation of NRC requirement i M1.3 Routine Surveillance Observations Insoection Scooe (61726)
The inspectors observed all or portions of the following surveillance tests: )
STP-073-2 Component Cooling Quarterly Test STP-O-73D-1 Charging Pump Performance Test STP-O-73F-1 Boric Acid Pump Performance Test STP-073K-2 Containrnent Spray Pump Operability 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 a pre-test briefing followed by a question and answer session attended by all test participants leaving clear test expectations with all involved. The test participants were knowledgeable of their assigned responsibilities. Supervisory and engineering personnel participation was clearly observed in the conduct of the surveillance tests. Minor test discrepancies were documented in the BGE corrective action program and correcte l Conclusions I
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 Activities q M8.1 (Closed) Violation 50-317 & 318/98-04-01: Failure to place the containment spray l system into (a)(1)
The violation was cited for failure to identify a repetitive functional failure which would have caused the system to be placed into the (a)(1) category of the maintenance rul Following NRC identification of the issue, BGE performed a root cause analysis and identified a problem with the software used to determine repetitive functional failure The software was modified and validation testing was completed. In addition, procedure MN-1-112, " Managing System Performance," was revised to include the system manager in the process for identifying functional failures and repetitive functional failure The inspector reviewed the root cause analysis and verified that the' corrective actions were completed. The inspector discussed the issue with the maintenance rule l coordinator. The BGE actions in response to the violation were appropriate and the 8 violation is close M8.2 (Closed) Violation 50-317 & 318/98-04-02: Failure to place several systems into the-(a)(1) category in a timely manner The violation was cited for failure to categorize several systems as (a)(1) in a timely manner following poor system performance. Following NRC identification of the issue, BGE performed a root cause analysis and determined that better guidance was needed for system managers for classifying systems as (a)(1). Procedure MN-1-112, " Managing System Performance," was revised to provide this guidance. The inspector reviewed the root cause analysis and the revised procedure. The inspector also discussed the issue with the maintenance rule coordinator. BGE actions in response to the violation were
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appropriate and the violation is close M8.3 (Closed) Violation 50-317 & 318/98-04-03: Failure to establish performance measures for the emergency diesel generator building HVA The violation was cited for failure to establish performance measures for the emergency diesel Generator building heating, ventilation, and air conditioning system. Following NRC identification of the issue, BGE performed a root cause analysis and identified a
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problem with their plant modification process. Procedure EN-1-100, " Engineering Service Process Overview," was revised to include the maintenance rule coordinator in l l the modification closeout process. The inspector reviewed the root cause analysis and l the revised procedure and discussed the issue with the maintenance rule coordinato BGE actions in response to the violation were appropriate and the violation is close M8.4 (Closed) Violation 50-317 & 318/98-04-04: Failure to include a portion of the Appendix R emergency lighting in the scope of the maintenance rule program The violation was cited for failure to include the Appendix R emergency lighting located outside the control room in the scope of the maintenance rule program. Following NRC identification of the issue, BGE performed a root cause analysis which identified 27
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Systems Structure Components (SSCs) that were added to the maintenance rule program after July 10,1996. The emergency lighting was identified to be placed into the program in June 1997. The inspector reviewed the root cause analysis, verified the emergency lighting was in scope and the system manager was monitoring performanc This issue was discussed with the maintenance rule coordinator. BGE actions in response to the violation were appropriate and the violation is close Ill. Ennineerina E1 Conduct of Engineering E1.1 Nuclear Fuel Desian Verification Inspection Scope The inspectors observed and discussed quality verification activities for used nuclear fuel with BGE engineering personnel, Observations and Findinos BGE initiated a design verification inspection for spent reactor fuel assemblies to check that critical performance expectations were met for clad oxide layer thickness and the absence of crud or unexpected corrosion. These eddy current and visual inspections were done with the fuel in the Calveit Cliffs spent fuel poo The initial examinations identified some blistering (sciling) of the clad oxide layer on some fuel pins where none was expected. The inspections also found a generally thicker oxide layer than expected for the given fuel bumup. Additional inspections and engineering analysis to fully characterize these indications and to evaluate potential causes were implemented by BGE. The preliminary evaluation included study of the effects of higher bumup and bumup rates for selected fuel pins. The unexpected oxide layer thickness was correlated with higher fuel duty cycles (temperature and local power). The oxide layer thickness could be an indication of hydrogen embrittlement in the zirconium based claddin BGE engineering personnel told the inspectors that a potential consequence of thicker oxide layer and spallation could include fuel exceeding its design basis in certain postulated core upset scenarios. The effects of the observations on the specific core analyses for Calvert Cliffs were being evaluated. While the observations were unexpected, the fuel currently in use in both units remained within its design and there were no curront operability concems. However, additional evaluation was needed for future duty of the current fuelin use and comparable past core designs. BGE told the inspectors that the fuel vendor was fully appraised of the finding BGE personnel documented their preliminary findings in Issue Report Number IR3-020- l 203. Engineering evaluation continued at the end of the inspection period. BGE told the
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inspectors that they intended to submit a licensee event report on this subject, even if their reviews did not find any reportable issue Conclusions BGE conducted testing of used nuclear fuel assemblies to confirm that the fuel remained within its design. Unexpected oxide layer thickness and some evidence of blistering were observed. The vendor was informed and further inspection was conducted. BE started an engineering evaluation to assure that reactor fuel remained within its design 3 limit E2 Engineering Support of Facilities and Equipment E2.1 Maintenance Rule Exoert Panel Meetina l
The inspectors observed an expert panel meeting on July 15,1990, and compared the 1 conduct of the meeting against the Maintenance Rule Expert Panel Charter included in Calvert Cliffs Administrative Procedure MN-1-112, " Managing System Performance."
The expert panel meeting was convened with multi-organizational representation (engineering, maintenance and operations) and expertise. The agenda and items discussed included: System (a)(1) evaluation, corrective actions and goal setting plan; a review of repetitive functional failures for 1999; and, revisions to the maintenance rule scoping document. Each issue was presented and discussed. Risk insights were provided by the Principal Engineer- Reliability Engineering Unit. The results of the meeting met the expert panel charter and were commensurate with safety goals of the maintenance rul E8 Miscellaneous Engineering issues E8.1 (Closed) Unresolved item 50-317/310498-80-01): Ventilation System Analysis and Reportability issues Inspection Scope A previously unresolved item concerning design validation of the control room and auxiliary building ventilation systems was reviewed and close Observations and Findinas
This unresolved item included six issues including analysis discrepancies and system performance issues discovered while BE conducted design validation work on the control room and auxiliary building ventilation systems. These issues were documented in NRC Inspection Report 50-317&318/98-80, as Unresolved item 50-337&338/98-80-01. The principle NRC concern involved the acceptability of BGE using analytical methods and design inputs not mentioned in the plant Final Safety Analysis Report 1 (FSAR), to analyze the effects of increased control room air inleakage and errors in the ,
original FSAR Chapter 14 offsite dose analysis for a Maximum Hypothetical Accident )
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(MHA). The inspector questioned whether a safety evaluation per 10 CFR 50.59 was appropriate. At the time the unresolved item was identified, it was not apparent to the inspectors that BGE had used the 50.59 process. A second concern involved whether increased air inleakage and analysis errors resulted in a condition that was outside of the plant design basis. On July 1,1999, the inspectors met with BGE to discuss the issues outlined in inspection report 50-337&338/98-01.
BGE's position regarding the control room ventilation system was that they had used the 50.59 safety evaluation process, and had concluded the increased control room air in leakage was an Unreviewed Safety Question (USQ). As such, they intended to update the FSAR once the NRC reviewed and approved the revised analysis, which was submitsd to the NRC in March 1998. BGE believed the current configuration was acceptable based, in part, on BGE operability assessments, conversations with the NRC technical staff, and NRC safety evaluations, which allowed the interim use of compensatory measures until full compliance with GDC 19 was achieved. Further, BGE indicated that since their operability assessment concluded the control room HVAC system was operable, the plant was within its design basis. BGE stated that once the control room analysis had been reviewed and accepted by NRC, the appropriate sections of the FSAR would be updated using the revised assumptions. BGE noted they had kept the NRC technical staff informed of their actions and have been able to meet most of the agreed upon commitment dates established in various correspondence with the NRC.
Regarding the errors in the Chapter 14 of' site dose analysis for a MHA, a recent BGE sensitivity study examined how the errors would affect the offsite dose analysis and concluded the errors were inconsequential and would not increase the offsite dose.
When performing the study, BGE used what they described as a more appropriate iodine partition coefficient to predict offsite dose consequences. When the original offsite analysis was performed by a third party vendor, a generic number value was used that did not precisely model Calvert Cliff's post accident lodine concentration. BGE indicated once the revised control room dose analysis was approved, they intended to revise their Chapter 14 MHA analysis, and provide it to the NRC for review.
Concerning the performance oeficiencies discovered while testing the auxiliary building ventilation systems; BGE indicated none of the issues constituted a condition that was outside of the plant design basis, since the systems were not relied upon to mitigate a MHA.
After reviewing the sensitivity analysis and some of the correspondence between the NRC and BGE regarding the control room ventilation system analysis, the inspectors concluded that BGE actions to date relative to updating the various analyses were appropriate. By submitting the revised control room analysis to the NRC for review, BGE was following the intent of the 50.59 rule. Further, since the auxiliary building ventilation systems were not used to mitigate a MHA, the performance deficiencies identified during testing did not constitute a reportable event per 10 CFR 50.72 or 50.73. Therefore, design issues that were associated with these systems are considered closed, and will not be considered violations of NRC requirement _ _ _ _ - _ _
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However, the inspectors did not agree with BGE's position that the increased control room air inleakage was not a condition outside of the plant design basis since the operability assessment relied on assumptions and coefficients that were not hscribed in the Calvert Cliffs FSAR. After reviewing this matter further, BGE made a 10 CFR Part 50.72 notification on July 2,1999, and filed a Licensee Event Report on July 30,199 In addition to the other activities mentioned above and to ensure future nonconforming
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conditions were properly reported, BGE licensing personnel indicated they would examine their procedures that provided guidance regarding reporting condition outside of the plant design basis and make appropriate changes. Licensee Event Report 50-317&378/99-03 is close However, BGE failed to make a timely report regarding a condition outside the design basis of the plant. This Severit: LevelIV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the BGE corrective action program as IR3-036-836. (NCV 50-317/318/99-06-02)
Unresolved item (URI 50-337&338/98-80-01) is closed.
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c. Conclusions BGE identified that control room ventilation in-leakage exceeded design values. The design calculations were later revised and submitted to NRC for review. The inspectors did not agree with BE that increased control room air in leakage was not a condition outside of the plant design basis since the operability assessment relied on assumptions and coefficients that were not described in the Calvert Cliffs FSAR. After the inspector's inquiry, BGE reported the issues in accordance with 10 CFR 50.72 and 10 CFR 50.7 Failure to make a timely report was a non-cited violatio s IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls On July 14,1999, the inspectors observed selected portions of an entry into the Unit 1 containment to take chemistry samples from the safety injection tanks. The pre-job brief i was thorough, detailed, and well conducted in accordance with a pre-planned check-off list. BGE personnel used good self-checking and peer-checking to verify that the required dosimetry was properly wom. Fire & Safety personnel provided heat stress calculations and confined space entry support. The containment entry was completed with no significant incident P3 EP Procedures and Documentation a. Inspection Scope I
Inspectors in the NRC Region I office reviewed Revision 27 which BGE had made to its onsite emergency response plan as well as several revisions made to some of the emergency response plan implementing procedures. They performed this review to determine whether BGE had made these revisions in accordance with NRC regulations.
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13 Observations. Findinas and Conclusions Based on the BGE determinations that the revisions had not decreased the effectiveness of its onsite emergency plan and that the emergency plan continued to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to Part 50, NRC approval of these revisions was not required. The inspectors' review of these revisions indicated them to be in accordance with 10 CFR 50.54(q). Implementation of these revisions remains subject to future onsite inspectio Conduct of Security and Safeguards Activities Insoection Scooe (81700)
The security program was inspected during the period of July 26-29,1999 to determine whether the conduct of security and safeguards activities met BGE's commitments in the NRC-approved security plan (the Plan) and other NRC requirements. Areas inspected included: alarm stations; communications; and protected area (PA) access control of personnel, packages and vehicle b. Observations and Findinas Alarm Stations. Operations of the Central Alarm Station (CAS) and the Secondary Alarm Station (SAS) were reviewed. Both alarm stations were determined to be equipped with appropriate alarms, surveillance and communications capabilities. Interviews with the alarm station operators found them knowledgeable of their duties and responsibilitie Observations and interviews also verified that the alarm stations were continuously manned, independent and diverse so that no singie act could remove the plant's capability for detecting a threat and calling for assistance, and the alarm stations did not contain any operational activities that could interfere with the execution of the detection, assessment and response function Communications. Document reviews and discussions with alarm station operators !
determined that the alarm stations were capable of maintaining continuous
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intercommunications, continuous communications with each nuclear security officer (NSO) on duty, and alarm station operators were testing communication capabilities with the local law enforcement agencies as committed to in the Pla Protected Area (PA) Access Control of Personnel. Hand-Carried Packaaes and Vehicles. On July 27 and 28,1999, during peak activity periods, personnel and package !
search activities were observed at the personnel access portal. Positive controls were determined to be in place to ensure only authorized individuals were granted access to the PA and that all personnel and hand-carried items entering the PA were properly searched. In addition, observation of multiple vehicle searches was accomplished. The vehicle searches were thorough and met the requirements of the Pla .. ..
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c. Conclusions BGE was conducting security and safeguards activities in a manner that protected public 1 health and safety in the areas of access authorization, alarm stations, communications, and protected area access control of personnel, packages and vehicles. This portion of the program, as implemented, met BGE's commitments and NRC requirement S2 Status of Security Facilities and Equipment a. Inspection Scooe (81700)
The areas inspected were protected area (PA) assessment aids, detection aids, and personnel search equipmen b. Observations and Findinas Assessment Aids. On July 27 and 28,1999, the effectiveness of the assessment aids was evaluated by observing the PA perimeter on closed circuit television (CCTV), in the CAS and the SAS, respectively. The evaluation of the assessment aids was accomplished by observing, on CCTV, an Nuclear security officer performing a perimeter patrol. The assessment aids had good picture quality, view and zone overla Additionally, to ensure Plan commitments were satisfied, BGE had procedures in place requiring the implementation of compensatory measures in the event the alarm station operator was unable to properly assess the cause of an alar PA Detection Aids. On July 27 and 28,1999, while observing the assessment aids, testing was also observed of selected intrusion detection zones in the plant protected area. The appropriate alarm was generated in each zone for each test. Through observations and review of the testing documentation associated with the equipment repairs, it was verified that repairs were made in a timely manner and that the equipment was functional and effective, and met the commitments in the Pla Eg_rgonnel and Packaae Search Eauioment. On July 28,1999, both the reatine use and the daily operational testing of BGE's personnel and package search equipment were observed. Personnel search equipment was being tested and maintained in accordance with licensee procedures and the Plan. Personnel and packages were being properly searched prior to PA acces Observations and procedural reviews determined that the search equipment performed in accordance with licensee procedures and Plan commitment Conclusions Security facilities and equipment in the areas of protected area assessment aids, protected area detection aids, and personnel search equipment were determined to be well maintained and were able to meet BGE's commitments and NRC requirement .
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83 Security and Safeguards Procedures and Documentation inspection Scope (81700) The areas inspected included security implementing procedures and event log Observations and Findinas Securiiv and Proaram Procedures.- Review of selected security program implementing procedures, associated with personnel search, vehicle search, and equipment testing verified that the procedures were consistent with the Plan commitment Security Event Loos. The Security Event Logs for the previous nine months were reviewed. Based on this review, and discussion with security management, it was determined that BGE appropriately analyzed, tracked, resolved and documented I safeguards events, Conclusions Security and safeguards procedures and documentation were being properly implemented. Event Logs were being properly maintained and effectively used to
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analyze, track, and resolve safeguards event Security and Safeguards Staff Knc t15 and Performance Insoection Scope (81700)
The area inspected was security staff requisite knowledge, Observations and Findinas Secunty Force Reauisite Knowledae. A number of Nuclear security officers in the performance of their routine duties were observed. These observations included alarm station operations, personnel and package searches, vehicle searches and exterior patrol alarm response. Additionally, Nuclear security officers were interviewed and based on the responses to questioning, it was determined that the Nuclear security officers were knowledgeable of their responsibilities and duties, and could effectively carry 7ut their assignment Response Capabilities. Review of documentation of contingency response drills and critiques disclosed that BGE is appropriately exercising this portion of the program. The review also disclosed that BGE is using lessons leamed from the drills to modify and refine the response plan to improve its effectivenes l l
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c. Conclusions The Nuclear security officers adequately demonstrated that they had the requisite knowledge necessary to effectively implement the duties and responsibilities associated with their positio S5 Security and Safeguards Staff Training and Qualifications a. Insoection Scoos (81700)
The areas inspected were security training,' qualifications and, record b. Observations and Findinas Security Trainina and Qualifications. On July 28,1999, training and qualification (T&Q)
records of ten nuclear security officers were reviewed. The results of the review indicated that these personnel were trained in accordance with the approved T&Q pla Trainina Records. Through review of training records, it was determined that the records were properly maintained, accurate and reflected the current qualifications of the nuclear security officer c. Conclusions Security force personnel were being trained in accordance with the requirements of the BGE training and qualification plan. Training documentation was properly maintained and accurate and the training provided by the training staff was effectiv S6 Security Organization and Administration a. inspection Scope (81700)
The areas inspected included security management support and staffing leyels, b. Qbservations and Findinas Manaaement Suooort. Review of program implementation since the last program inspection disclosed that adequate support and resources continued to be available to ensure effective program implementatio Staffina levels. The total number of trained Nuclear security officers immediately available on shift met the requirements specified in the Plan and implementing procedure ,
c. Conclusion The level of management support was adequate to ensure effective implementation of the security program, and was evidenced by the allocation of resources to support programmatic need S7 Quality Assurance (QA)in Security and Safeguards Activities a. Inspection Scope (8170.0)
The areas inspected were security audits, problem analyses, corrective actions, and effectiveness of management control j b. Observations and Findinos Audits. A review of the most recent annual security audit (98-08, November 1998) and the Fitness for Duty (FFD) audit (99-02, March 1999) was conducted. This review disclosed that the audits were comprehensive in scope and depth. Both audits were enhanced by the use of outside technical specialist Problem Analyses. A review of data derived from the security department's self-assessment program indicated that potential weaknesses were being properly identified, tracked, and trende Corrective Actions. Review of corrective actions implemented by BGE, in response to the QA audits and self-assessment program, disclosed that all corrective actions had been implemented and were effectiv Effectiveness of Manaoement Controls. BGE had programs in place for identifying, analyzing and resolving problems. They include the performance of annual QA audits, a 1 departmental self-assessment program and the use of industry data, such as violations l of regulatory requirements identified by the NRC at other facilities, as a criterion for self-assessmen c. Conclusions The review of BGE's security audit program indicated that the audits were comprehensive in scope and depth, that findings were reported to the appropriate level of management, and that the program was being properly administered. In addition, a review of the documentation applicable to the self-assessment program indicated that the program was being effectively implemented to identify and resolve potential weaknes ,
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V. Manaaement Meetinos X1 Exit Meeting Summary At the conclusion of the inspection, on August 31,1999, the inspectors presented the inspection results to Mr. Katz and others of BGE management. BGE acknowledged the findings presented. Preliminary exit meetings for the control room ventilation, security, and the maintenance rule open item inspections were conducted on July 1, July 27, and July 29, respectivel i l
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ATTACHMENT 1 Enttial List of Persons Contacted B.QE C. Cruse, Vice President, Nuclear Energy Division P. Katz, Plant General Manager K. Cellars, Manager, Nuclear Engineering L. Wechbaugh, Superintendent, Nuclear Maintenance B. Montgomery, Director, Nuclear Regulatory Matters S. Sanders, General Supervisor, Plant Engineering T. Sydnor, General Supervisor, Plant Engineering D. Holm, General Supervisor, Plant Operations T. Pritchett, Superintendent, Technical Support L. Smialek, Radiation Protection Manager f C. Earls, General Supervisor, Radiological / Chemistry J. Lemons, Manager, Nuclear Support Services A. Edwards, Director, Nuclear Security NBC M. Evans, Chief, Division of Reactor Projects Branch 1 INSPECTION PROCEDURES USED IP 71707 Plant Operations IP 62707 Maintenance Observation IP 61726 Surveillance Observation IP 37551 Onsite Engineering IP 71750 Plant Support Activities IP 82701 Operational Status of the Emergency Preparedness Program IP 81700 Physical Security Program for Power Reactors
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Attachment 1 (cont'd) 2 ITEMS OPENED. CLOSED. AND DISCUSSED Opened / Closed 50-337&338/99-06-01 NCV Failure to document problems with diesel generator maintenance in the Maintenance Order 50-337&338/99-06-02 NCV Failure to promptly report a condition outside of the design basis of the plant Closed i
50-317&318/98-04-01 VIO Failure to place the containment spray system into (a)(1) i j
50-317&318/98-04-02 VIO Failure to place several systems into the (c)(1)
category in a timely manner 50-317&318/98-04-03 VIO Failure to establish performance measures for the emergency diesel generator building HVAC 50-317&318/98-04-04 VIO Failure to include a portion of the Appendix R emergency lighting in the scope of the maintenance rule program 50-317&318/98-80-01 URI Engineering issues: Control Room Heating, Ventilating, and Air Conditioning Design Basis 50-317&318/99-03 LER ~,
Use of Unapproved Methodology Puts Plant Outside ofits Design Basis l
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Attachment 1 (cont'd) 3 LIST OF ACRONYMS USED AOP Abnormal Operating Procedure BGE Baltimore Electric and Gas CAS central alarm system CCTV closed circuit television eel Escalated Enforcement item FFD fitness-for-duty FSAR Final Safety Analysis Report HVAC heating, ventilating, and air conditioning LER Licensee Event Report MHA Maximum Hypothetical Accident NCVs Non-Cited Violations j NSO Nuclear Security Officer i PA protected area PDR Public Document Room POSRC Calvert Cliffe Plant Operational Safety Review Committee QA quality assurance RO (licensed) reactor operator RP&C Radiological Protection & Chemistry SAS secondary alarm system i SRO (licensed) senior reactor operator SSCs Systems Structure Components T&Q training and qualification the Plan NRC-approved physical security plan URI Unresolved item USQ Unreviewed Safety Question VIO . Violation
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