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BALTIMORE*,*

OAS AND| ELECTRIC

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CHARLES CENTER . P.O. BOX 1475 BALTIMORE, MARYLAND 21203 +

LEON B. RUSSELL !

MANAGERCCAvt01 CLIFFS NUCLE AN POWER PLANT DEPARTMENT *

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|; January 26, 1990,

U. S. Nuclear Kegulatory Commission Docket Nos. 50-318 i

Document Control Desk License Nos. DPR 69 '

Washington, D. C. 20555

Dear Sirs:

The attached LER 89-22, Revision 0, is being sent to you as required under 107CFR 50.73 guidelines.

Should you have any questions regarding this report, we would,be pleased todiscuss them with you.

Very truly yours,

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/t4ML . B . Ri. n ' 1. -iManager Gal mrt Cliffs Nuclear Power Plant Department

CDS/lr

| cc: William T. RussellDirector, Office of Management.Information

and Program ControlMessrs: G. C. Creel

C. H. Cruse! R. E. Denton .

J. R. Lemons

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ADjiTRACT

On December 27, 1989, at 1415 hours, a Technical Specification (TS) violation wasdiscovered to have existed at Calvert Cliffs Unit-2. The violation was the result of j

performing core alterations and/or movement of irradiated fuel within containmentwithout assuring that both containment vent isolation valves were closed in accordance ;

with TS 3/4.9.14'

The immediate cause of the event was n' procedural deficiency. One of the containmentvent valves was erroneously deleted from the STP which satisfied TS 4.9.14. The rootcause was an error in a review to assure that the STP satisfied the TS limitingconditions for containment penetrations during core alternations or movement of

| irradiated fuel within containment. The error resulted from a failure to recognize !! that a double valve isolation is required for the containment vent penetration in MODE ;

6. The error resulted in the deletion of one of the redundant valves from the MODE 6STP to verify containment integrity.

The STP's for both units were revised to include the deleted valves. The valves willbe flagged referencing the Basis section of the Technical Specifications. The Surveil-lance Test Program instruction has been revised to reduce occurrence of such events.

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|I. DESCRIPTION OF EVENTS

On December 27, 1989, at 1415 hours, a Technical Specification (TS) violationwas discovered to have had existed at Calvert Cliffs Unit-2. The violation was -

the result of performing cor' . iterations and/or movement of - irradiated fuel |within containment without asm.ing that both containment vent' isolation valves

were closed in accordance with TS 3/4.9.14 The event was-discovered during aconcentrated effort to identify discrepancies between TS's and associatedSurveillance Test Procedures (STP's). At the time the event was discovered.Unit-1 was in cold shutdown with the reactor coolant- system at 105 F and 10 psigand Unit 2 was defueled.

Calvert Cliffs TS 3.9.14 requires that during core alterations or movement of:irradiated fuel within the containment, the containment vent isolation valvesshall be closed. There are two containment vent isolation valves, MOV-6900(inside containment) and MOV-6901 (outside containment). TS 4.9.14 requiresthat the containment vent isolation valves be determined to be closed within 72hours prior to the start of, and at least once per 7 days during, corealterations or movement of irradiated fuel within the containment, j

Surveillance Test Procedures 0-55A-1 and -2 are titled, " Containment Integrity,

Verification (Mode 6)". These procedures were originally created to satisfy - therequirements of TS 3/4.9.4, " Refueling Operations, Containment Penetrations". iTS 3.9.4 requires that during core alterations or movement of irradiated fuelwithin the containment that each penetration providing direct access from }containment to outside shall be either;

1. Closed by an isolation valve, blind flange, or manual valve, orj,

i| 2. Be capable of being closed by an operable automatic containment purge

valve.|

| TS 4.9.4 requires verification of the above within 72 hours prior to the starti of, and at least once per 7 days during, core alterations or movement of

irradiated fuel inside containment. !i

Due to the similarity between TS 3/4.9.4 ,and 3/4.9.14 and their surveillancerequirements, they are both included in STP 0-55A-1 and 2. The major differencebetween the two is that TS 3/4.9.14 requires a double isolation of the-

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containment vent containment penetration during refueling operations while TS i

3/4.9.4 requires only a single isolation of all other containments penetrations, i

TS 3/4.9.4 is part of the original Calvert Cliffs Technical Specifications. TSi 3/4.9.14 was added to Unit-1 and -2 TS's .as part of amendment 88 and 75,| respectively. These TS amendments became effective on November 17, 1983 and| June 6,'1984 for Units 1 and 2, respectively. .Both Units had appropriate changes

made to STP 0-55A to include both MOV-6900 and 6901.

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During the first quarter of 1987, a review of all penetrations that could providea direct flow path from inside to outside containment was conducted. The intentof this review was to provide increased confidence that a direct path could notbe inadvertently created through a penetration that could be overlooked duringcore alterations. A set of acceptance criteria was established. One of theseacceptance criteria was to identify all penetrations that could provide a directflow path from inside to outside containment and assure that all suchpenetrations were isolated by at least one valve, blank flange, or

other approved barrier.

The penetration review determined that penetration 48A, the containment ventoutlet, provided a direct path to the plant vent system (outside containment).It was therefore concluded that the MOV-6900 should be maintained shut. It was

not recognized that TS 3/4.9.14 required both MOV-6900 and 6901 to bemaintained closed in MODE 6. STP 0-55A-2 was revised to reflect the findingsof the review. STP 0 55A-2, revision 11, dated April 10, 1987 deleted Unit-2MOV 6901 based on the above noted review and STP 0 55A-1, revision 13, datedMarch 1, 1989 deleted Unit-1 MOV-6901.

After the deletion of MOV-6901 from STP 0-55A 1 and -2, each STP was performedseveral times. STP 0-55A-1 was performed twice, but not for core alterationpurposes. Thus, no violation of TS 3/4.9.14 actually occurred for Unit-1. STP0-55A-2 on the other hand, was performed several times for the purposes ofallowing-core alterations during Unit-2 outages between March and July 1987 andbetween March 1989 and present. Thus, several violations of Unit-2 TS 3/4.9.14did actually occur.

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| II, CAUSE OF EVENT

The cause of this event was procedural deficiency. The procedures, STP 0-55A-1and 2, did not contain both containment vent isolation valves MOV-6900 and 6901.

,The root cause 4 the event was an error in the previously discussed 1987 review

! of penetratior. that could provide a direct path from inside to outsidecontainment. Tim review was done to assure that the single isolation conditionsof TS 3/4.9.4 were satisfied for all containment penetrations, but did notrecognize the required double isolation of the containment vent isolation valves.This led to the deletion of the redundant containment isolation vent valveMOV-6901 from STP 0-55A-2 on April 10, 1987 and from STP 0-55A-1 on March 1,1989.

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III. AH6LLSI.S OF EVENT

The event is considered reportable under 10 CFR 50.73(a)(2)(1)(B) because corealterations were performed for Unit-2 during outages in 1987 and 1989 without -verifying that both containment vent isolation valves were closed in accordancewith TS 3/4.9.14. There was no such violation of the TS for Unit 1 becauseno core alterations or movement of irradiated fuel were performed during theperiod that MOV-6901 was removed from STP 0 55A-1.

TS 3/4.9.14 was added to Unit 1 and -2 TS's by amendments 88 and 75,respectively. The valves . were formally designated as hydrogen purge outletvalves. The TS amendments proposed that the hydrogen purge outlet valves be :re designated as containment vent isolation valves, and be required to closeautomatically in less than 20 seconds as verified by periodic testing.

In Modes 5 and 6, the TS amendment proposed the addition of the TS .3.9.14.This new TS required both containment vent isolation valves remain closedduring core alternations or mov'ement of irradiated fuel within containment. Thebasis for this requirement is that the closure restrictions- on these valves aresufficient to restrict radioactivo material release from a fuel element rupturebased upon the lack of containment pressurization potential while in therefueling mode,

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TS 3.9.4 addresses the required status of all other containment penetrations inmodes 5 and 6. The TS requires a single isolation . of all applicablecontainment penetrations by an isolation valve, blind flange, or manual valve.The basis for this requirement is that the closure restrictions are sufficient torestrict radioactive material release from a fuel element rupture based upon the

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lack of containment pressurization potential while in the refueling mode.'

It is concluded that no adverse safety consequences resulted from.this event, Atall times during core alterations and movements of irradiated fuel withincontainment the TS surveillance requirement was satisfied for MOV-6900. Thus,i

| sir.gle isolation of this particular containment penetration was maintained. The| single closed isolation valve would have effectively prevented the- release of| radioactive material from a fuel element rupture in the refueling mode. Why TS| 3/4.9.14 requires double isolation of a containment penetration and TS 3/4.9.4

requires only single isolation of similar penetrations is unknown.i- +

The total duration of MOV-6901 being deleted from STP 0-55A-2 was from April 10,1987 . to November 2, 1989,'a total of two and one-half years. There .were nocomponents or systems which were inoperable and/or out of service- whiahcontributed to this event. No plant systems or component failures resulted from

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IV. CO'1RECTIVE ACTIONS

1. Effective November 2, 1989, STP 0-55A-1 and 2 were revised to includeMOV 6901,

2. MOV 6900 and 6901 will be flagged in STP 0 55A 1 and 2 referencing it tothe Basis section of the Technical Specifications.

3. The Surveillance Test Program instruction has been revised to reduceoccurrence of events such as the deletion of MOV-6901 fror. 0-55A-1 and 2.Changes include the addition of Functional Surveillance Test Coordinators(FSTCs) who are responsible for coordinating the preparation of STPs andrevisions to STPs. The FSTCs provide focused, discipline-specific controlof surveillance test content, review and scheduling.

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V. ADDITIONAL INFORMATION I

There have been several previous reportable events caused by inadequate,incomplete, or lack of procedures at Calvert. Cliffs. However, no previoussimilar reportable events have occurred at Calvert Cliffs involving inadvertentdeletion of TS requirements from STP?s.

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Identification of Components Referred to in this LER-

Component 'IEEE803 IEEE805EIIS Funct. System ID i

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(1) MOV-6900 VTV BB

(1) 2 MOV-6901 VTV BB

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