ML20038C736
| ML20038C736 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/25/1981 |
| From: | Architzel R, Mccabe E, Rhoads G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20038C723 | List: |
| References | |
| 50-317-81-22, 50-318-81-21, NUDOCS 8112140086 | |
| Download: ML20038C736 (5) | |
See also: IR 05000317/1981022
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
50-317/81-22
Report No.
50-318/81-21
50-317
Docket No.
50-318
C
License No.
Prierity
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Category
C
Licensee:
Baltimore Gas and Electric Company
P.O. Box 1475
Baltimore, Maryland 21203
Facility Name: Calvert Cliffs Nuclear Power Plant, Units 1 ar.d 2
Inspection at: Lusby, Maryland
Inspection conducted: October 22 - October 30, 1981
Inspectors:
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G. G. Rhoads, FIeactor Inspector
date signed
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R. E. Architzel, S,enior Resident Inspector
date signed
Approved by:
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E. C. McCabe, Jr. , Cnief, Reactor Projects
date signed
Section 28, DRPI
Inspection Su mary:
Inspection on October 22 - October 30, 1931 (Combined Report Nos. 50-317/S1-22
and 50-318/81-21)
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Areas Inspected:
Routine, onsite inspection of valve failure mode by a Region
I inspector and by the resident inspector.
Three violations were identified:
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Failure to change containment isolation valve failure mode for over 5 years;
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Failure to take measures to preclude recurrence of improper valve f ailure
mode; Electrical schematics showed wrong containment isolation valve f ailure
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mode.
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86 812197
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OETAILS
1.
Persons Contacted
The following technical and supervisory level personnel were contacted:
- J.
T. Carroll, General Supervisor, Operations
- W.
C. Gibson, General Supervisor, Electrical and Controls
'O. W. Latham, Principal Engineer, Operational, Licensing and Safety
Unit
P. G. Rizzo, Assistant General Foreman, Maintenance
- L.
B. Russell, Plant Superintendent
J. Sites, Supervisor, Instrument Maintenance Unit 1
J. A. Snyder, Supervisor, Instrument Maintenance Unit 2
- J. A. Tiernan, Manager, Nuclear Power Department
W. L. Whitaker, Assistant General Foreman, PMD
- Attended exit on Octob9r 30, 1931.
Other licensee employees were also contacted.
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2.
Review of Events Requiring One Hour Notification to the NRC
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On October 22, 1931 at 3:30 p.m. the licensee declared the Unit One
air-operated Component Cooling Water supply valve to containment
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(1-CC-3832-CV) inoperable after realizing it would fail OPEN on loss of
instrument air.
The licensee reported this to the NRC Emergency
Operations Center at 4:25 p.m., and began a reactor shutdown.
The valve
was declared operable at 8 p.m. after the licensee had modified the
actuator to cause the valve to f ail SHUT on loss of air.
About 10:30
p.m.,
October 22, 1981 the inspector reviewed the following:
FSAR Table 5-2, Sheet 2 of 4; FSAR Figure 7-10, Sheet 2; FSAR Figure 9-6;
FSAR Figure 9-25.
No difference was found between Unit 1 (Valve 1-CC-3832-CV) and Unit 2
(Valve 2-CC-3821-CV).
The inspector then examined the Unit 2 solenoid
for Valve 2-CC-3332-CV and noted it appeared to be deenergized with the
valve OPEN.
Ha asked the Shift Supervisor about that.
The Supervisor
stated that Instrument and Control Technicians had examined the Unit Two
valve and determined that it would fail SHUT on loss of air or of
electrical poner to the solenoid.
The inspector told the General
Supervisor, Operations about his examination of the solenoids and
schematics, and about his conclusion that the Unit Two valve would fail
OPEN on loss of air and electrical power.
About 2:50
a.m., October 23, 1981, after further review, the licensee
declared t',e Valve 2-CC-3832-CV inoperable after determining it failed
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OPEN on loss of air or electrical power.
This was reported to the NRC
Emergency Operations Center at 3:40 a.m.
The valve actuator was modified
to fail the valve SHUT on loss of air or electrical power; Valve
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2-CC-3832-CV was declared operable at 9:30 a.m.
The inspector witnessed
parts of the post-maintenance testing and found no discrepancies.
On October 27, 1981 the inspector reviewed MR's (Maintenance Requests)
MSl-432 for the work performed on the Unit One valve, and IM-81-2127 for
the work performed on the Unit Two valve.
Both MR's referenced Field
Change Request FCR 75-1089, Revision Two, originated September 2, 1976.
It stated that it revised FSAR Table 5-2 to show the valve as
fail-closed, revise FSAR Figure 5-10, and changed the pneumatic failure
mode of the valve. The stated reason was that failing closed was the
conservative failure mode and would provide additional isolation
capability. The FCR work description states that the FCR made
1-CC-3832-CV fail closed on loss of air and on loss of electrical power.
FCR 75-1089, Revision 2, was not approved by the Plant Operating Safety
Review Committee until October 22, 1981, over five years from the time it
was initiated.
10 CFR 50 Appendix B Criterion XVI requires measures for
promptly correcting conditions adverse to quality.
Failure to process
FCR 1089 for more than five years violates that requirement.
(317/81-22-01)
The inspector questioned the General Supervisor, Operations, on how Valve
1-CC-3832-CV had been determined to be inoperable.
The Supervisor stated
that, while investigating a problem with ASCO solenoid valves, the
licensee had determined that the Unit One CCW supply valve to containment
would fail OPEN.
Upon further investigation, the licensee determined
that CCW inside containment was not considered safety-related, and was
therefore not seismically qualified.
Instrument air to the valve
actuator was also not seismically qualified.
Consequently, a seismic
event could cause a CCW line break inside containment and also cause CCW
Containment Supply Valve 1-CC-3832-CV to fail 0 PEN. CCW could then empty
into containment; its safety-related functions would be lost.
outside containment supplies water to the low and high pressure coolant
injection seals and cooling water to the shutdown cooling heat exchangers
(which cool Containment Spray).
The inspector verified that the "Q" drawing for Unit One CCW showed that
the boundary for the safety-related portion of the CCW system did not
include piping inside containment.
On October 27, 1981 the Principal Engineer, Electrical Engineering
Department, stated that CCW since containment t.as a "two over one"
system, meaning that it should not fail and damage any+.hing seismic. The
inspector asked if the piping was supported so that it would not break
during a seismic event. The Principal Engineer stated that this was not
the intent of the "two over one" concept, but rather that the pipe would
be restrained so that it could not affect seismically qualified systems.
On October 30, 1981 the licensee showed the inspector a March 13, 1974
letter (serial CC-5639) from Bechtel Power Corporation to the Project
Engineer of Baltimore Gas and Electric Company.
The letter stated that
Bechtel had performed a seismic analysis on the CCW system and it could
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be considered seismically qualified. The licensee' stated they planned to
review all CCW maintenance since March 1974 to show whether the seismic
capability had been altered. That data will be reviewed when available.
On October 27, 1981 the inspector asked the General Supervisor,
Electrical and Controls, why the Unit Two valve had not been determined
to be inoperable before the inspector discovered the deenergized
solenoid. The Supervisor stated that the technicians had verified that
the air supply and vents were connected to the solenoid valve the same
way as in Unit One but did not verify the electrical hookup.
The
Supervisor also stated that no electrical work had to be performed on
Unit One's solenoid valve since it would~have failed SHUT on loss of
electrical power.
On October 28, 1981 the inspector reviewed controlled electrical
schematic lE-76, Sheet 14G, Revision 1, February 16, 1977.
It showed
that the solencia valve ICV-3832 was electrically connected to fail OPEN
on loss of electrical power. The inspector next reviewed documentation
of work performed on valve 1-CC-3832-CV since 1972. On July 24, 1973 a
control valve and actuation information sheet had been filled out
indicating the valve would fail OPEN on loss of air, but did not indicate
how it would fail on loss of electrical power.
No other work was
documented for the valve's electrical power. A controlled drawing,
(IE-76, Sheet 14G, Revision 1, February 16,1977) indicated the valve
should be electrically connected to fail OPEN on loss of electrical
power, but the licensee had found the valve to be connected electrically
to fail SHUT on loss of electrical power.
10 CFR 50 Appendix B Criterion
IV requires appropriate drawings for activities affecting quality. This
violates that requirement (317/81-22-02).
On October 29, 1981 the inspector asked the Assistant General Foreman,
Maintenance, and the Principal Engineer, Operational Licensing and Safety
Unit, why FCR 1089, had taken so long.
The Principal Engineer stated
that the FCR may have been misfiled at the plant because it first
discusses an FSAR table (Table 5-2) which needed updating.
The Principal
Engineer theorized that the FCR was then given a low priority for
completion due to the FSAR needing updating only.
The Assistant General
Foreman, Maintenance showed the inspector a Responsible Engineer February
1981 Field Change Request computer list which indicated that construction
was complete for FCR 1089, Revision 2 and on October 1,1981 Facility
Change Request Data Base which showed FCR 1089, Revision 2. He stated the
Responsible Engineer computer list was apparently in error, but he had
not been able to track down when the error had been made.
In addition to requiring measures for prompt correction of conditions
adverse to quality, 10 CFR 50 Appendix B Criterion XVI requires that
corrective measures be taken to preclude recurrence.
Since the licensee
corrective measures did not address the sa.ne problem on Unit 2, the
measures to prevent recurrence were not adequate and violate NRC
requirements. (317/81-22-03; 318/81-21-01)
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3.
Review of Licensee Event Reports (LER's)
The inspector reviewed LER's submitted to NRC:RI to verify that the
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details of the event were clearly reported, including the accuracy of the
description of cause and adequacy of corrective action. The inspector
determined whether further information was required from the licensee,
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whether generic implications were indicated, and whether the event
warranted onsite followup.
The following LER's were reviewed.
LER No
Date of Event
Date of Report
Subject
81-74
October 22, 1981
October 23, 1981
Inoperability
(Unit One)
of
Component
Cooling
Isolation
Valve.
81-45
October 23, 1981
October 23, 1981
Inoperability
(unit Two)
of Component
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Cooling
Isolation
Valve.
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For both LER's, the inspector verified that appropriate corrective action
was taken or responsibility assigned and that continued operation of the
facility was conducted in accordance with Technical Specifications and
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did not constitute an unreviewed safety question as defined in 10 CFR 50.59.
Report accuracy, compliance with current reporting requirements,
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and applicability to other site systems and components were also
reviewed.
See Paragraph 2 for further details.
4.
Exit Interview
Meetings were held with senior facility management on October 30, 1981
to discuss the inspection scope and findings.
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