IR 05000317/1992080

Ack Receipt of 920708,0814 & 0914 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-317/92-80 & 50-318/92-80.Two Violations Retracted & Third Violation Modified

ML20056C128
Person / Time
Site:	Calvert Cliffs
Issue date:	03/22/1993
From:	Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Denton R BALTIMORE GAS & ELECTRIC CO.
Shared Package
ML20056C129	List: IR 05000317/1992080 ML20056C133
References
NUDOCS 9303300129
Download: ML20056C128 (4)

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Docket Nos. 50-317 50-318  ;

l Mr. Roben l Vice President - Nuclear Energy '

Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant MD Rts 2 and 4, Post Office Box 1535  !

Lusby, Maryland 20657

Dear Mr. Denton:

SUBJECT: RESPONSE TO ELECTRICAL DISTRIBUTION SYSTEM FUNCTIONAL INSPECTION (EDSFI) OF CALVERT CLIFFS UNITS 1 AND 2, ,

COMBINED INSPECTION REPORT NOS. 50-317/92-80 AND 50-318/92-S0 ,

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l This letter replies to your letters dated July 8, August 14, and September 9,1992, in !

response to our letter dated June 5,1992, and subsequent clarifications by phone during late ,

January and early February 1993.  !

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Thank you for informing us of the corrective and preventive actions documented in your letter and of the dates for the resolution of the identified issues. These actions will be examined during a future inspection of your licensed program. .

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As requested in your letter, " Reply to a Notice of Violation," we have reconsidered the ,

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violations. Upon further review, we have retracted two violations and modified the third violation. Our bases for this determination are described below.

l In your response to the first violation (92-80-001), first example, where we cited you for not l controlling the degraded grid relay reset points, in accordance with Criterion XI of 10 CFR - ,

50, Appendix B, we concur with your explanation in your response that the actual degraded )

voltage relay acceptance value is still within the design margin considering the instrument j tolerance. The as-found value of 105.77 volts relay reset value, per your design, did not l represent a potential challenge to safety systems. However, you failed to properly control the relay reset to within the vain prescribed by your procedure. Therefore, this violation >

has been modified to address this issue and is attached as Appendix A. You are required to respond to the Notice of Violation (NOV) and, in preparing your response, you should follow the instructions included.

OFFICIAL RECORD COPY - A:RCCEDSFI.RM 9303300129 930322 PDR ADOCK 05000317

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MAR 2 21993

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Mr. Robert :

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The first violation, second example, pertained to your failure to record and evaluate the }

highest frequency reached during the emergency diesel generator (EDG) eighteen-month  !

L su veillance test. We noted that the test record for the surveillance test procedure (STP)

stated that the highest frequency reached during loading was 61 Hz, but our review of the visicoder chan showed that it was at least 66.2 Hz during step zero. In your response, you stated that you do not consider step zero (EDG breaker close) as a load sequence step since the loads applied at this step have minimal impact on the transient. You also stated that the j observed frequency (66.2 Hz) at step zero was within the frequency requirements and intent l (66.7 Hz) of Section 8.4.1.2 of the UFSAR for step changes and, therefore, technically  !

acceptable. We also note, through your phone call clarification on January 27,1993, and [

subsequent review of your additional surveillance procedure STP-0-8C-1, " Semi-Annual Test j of 11 Diesel Generator and 114 kV Bus LOCI Sequencer Review," that you conduct other j testing to assure that the EDGs can maintain frequency during a cold fast start with no load. j

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We accept your explanation that surveillance test STP-0-4 documented the maximum i frequency observed during EDG load sequence steps. Based on your additional information }

and further clarification of this concern, the first violation, second example, is retracted. j a >

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In your response to the second violation (92-80-002), you stated that no requirement exists in l Regulatory Guide 1.33, Revision 2, Appendix A, to include instrument inaccuracies and [

calibration errors in surveillance procedures. We have reviewed requirements and agree that l

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l the above requirement is not contained in the Regulatory Guide as originally stated in the violation. The requirement, as specified in 10 CFR 50, Appendix B, Criterion XI, is to use {

l instrumentation appropriate for the measurement. Also, during our January 27,1993, phone l 1 call, you reported that two kilowatt meters mentioned on page 43 of our report were within l

calibration at the time of the inspection. The 100KW difference in meter readings was due  !

4 to instrument inaccuracies. Based on the above, we retract the second violation. j

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i In your response to the third violation, first example (92-80-003), after reviewing your

additional information and reaffirmation that the margins are pesent in these cases, we l retract the references to the first three assumptions listed in the NOV. We also acknowledge  !

i that the errors that led to the remaining two erroneous assumptions were caused by failure to

follow procedures and not a failure to check or verify the adequacy of the design. l

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In your response to the third violation, second example, you stated that "no regulatory

- guidance specific to the treatment of instrument inaccuracy is cited in the NOV...." We j

agree and retract the violation. The underlying issue is do you need to consider instrument j inaccuracies considering the tight design margin in your EDG capacity and degraded grid j voltage protection. You reaffirmed, during our January 27,1993, phone call, that you have j 1 adequate margin for the EDGs. We also understand that you will update your c:'culations, including the EDG loading calculation, by the end of June 1993. We plan to review the final  !

calculations to confirm the margins and corrective actions cited in your response letters in l our followup inspection.

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J l l OFFICIAL RECORD COPY - RCCEDSFI.RM l

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RAR 2 21933 .!

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Mr. Robert If you do not agree with any reference we have made to the January 27,1993, phone call, please include your additional information in your response letter.  ;

Your cooperation with us in this matter is appmciated.

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Sincerely,

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Marvin W. Hodges, Director l Division of Reactor Safety l

i Enclosure: Appendix A, Notice of Violation ':"

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i cc w/ encl: .;

G. Detter, Director, Nuclear Regulatory Matters (CCNPP) l R. McLean, Administrator, Nuclear Evaluations l J. Walter, Engineering Division, Public Service Commission of Maryland l K. Burger, Esquire, Maryland People's Counsel R. Ochs, Maryland Safe Energy Coalition l Public Document Room (PDR) l

Iocal Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC) -l NRC Resident Inspector 4 State of Maryland (2) i

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OFFICIAL RECORD COPY A:RCCEDSFI.RM  !

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l MAR 2 21993

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Mr. Robert