ML19276G888
| ML19276G888 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/20/1979 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7908280554 | |
| Download: ML19276G888 (4) | |
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. 4f B ALTIMORE G AS AND ELECTRIC COMP ANY P.O. B O X 1475 B A LTI M O R E. M A R YL A N D 2120 3 AmTHun E:. LUNOVALL.JR.
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Swwsv August 20, 1979 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. Robert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors
Subject:
Calvert Cliffs Nuclear Power Plant Docket Nos. 50-317 and 50-318 IE Bulletin 79-06B
References:
(1)
A. E. Lundvall, Jr. to Boyce H. Grier letter of April 26, 1979, same subject (2)
A. E. Lundvall, Jr. to Boyce H. Grier letter of May 8,1979, same subject (3)
A. E. Lundvall, Jr. to R. W. Reid letter of June 5,1979, same subject Gentl emen:
By means of a telephone conversation on August 9,1979, your Mr. E. L.
Conner, Jr. reouested further infonnation recarding certain items of References (1) and (2). Specifically, Mr. Conner asked us to further document to you, in writing, certain actions we have taken to comoly wi d1 the recuirenents of the subject IE Bulletin. Additionally, docu-mentation of our action, to date, was reouested for the reouirements of IE Bulletin 79-06C. Our action recarding the specific items discussed is set forth below.
ITEM 2.c 0F IE BULLETIN 79-06B RE00EST:
Document procedure changes which have been made to enhance core coolina should voids be formed.
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IE BULLETIf4 79-06B 2
RESPONSE
The appropriate plant Emergency Operating Procedure (E0P-5, Loss of Reactor Coolant) has been revised to emphasize the importance of assuring core cooling, as discussed in detail by Reference (3).
(This action has recently been modified by the requirements of IE Bulletin 79-06C, as discussed below). As stated by Reference (3), the procedure requires the maintenance of steam generator water levels as a heat sink in the event core voiding occurs. Additionally, in a small break situation, the procedure requires the continued operation of HPSI pumps to restore pressurizer level and pressure such that subcooled, natural circulation conditions are established.
ITEM 3 0F IE BULLETIfl 79-06B RE00EST:
Provide results of design review concerning containment isolation.
RESPONSE
The design review has been comoleted by the Electric Enoineering Depart-ment and our Architect-Engineer has been directed to proceed with a cost estimate and detailed desion to transfer certain isolation functions from a Containment Isolation Signal (CIS) to a Safety Injection Isolation Signal (SIAS). These functions are: Containment flormal Sumo Drain, Reactor Coolant Sample (includes Pressurizer, Quench Tank and Orain Tank),
Containment Purge Supply and Exhaust, Containment Radiation Monitor, Deactor Ccolant Drain Tank effluent, Containment Heating, and Quench Tank Naste Gas vent. Additionally, a desion is being developed to assure a coolina water flow to the Reactor Coolant Pumns based on a logic-actuation system which will allow the isolation valves to remain open so lona as the Component Cooling Water system remains coerable (unaffected by a seismic event).
ITEM 10 0F IE BULLETIfl 79-06B RE00EST:
Provide a documented commitment stating the specific in-plant provisions which have been instituted to notify the f!RC "within one hcur of the time the reactor is not in a controlled or excected condition of operation".
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IE BULLETIN 79-06B 3
RESPONSE
As set forth in Reference (1), our original comitment to make a one-hour report was based on the initiation of the ECCS system. The appropriate plant emergency operating procedures have been revised to include this requirement.
In phone conversations with your Mr. E. L. Conner, Jr. on July 12 and August 9,1979, we were informed that this commitment did not provide a low enough " threshold" to satisfy the intent of the bulletin requirement. However, on those occasions, Mr. Conner was not able to provide specific guidance regarding criteria which would provide a satis-factory threshold. Additional conversations on the same subject with Mr.
D. F. Johnson of Region I, I&E, indicated similar concerns as those expressed by Mr. Conner; nonetheless, Mr. Johnson also could not provide specific cuidelines.
In addition to a lack of guidance as to what specific plant conditions would meet the intent of the bulletin item for reporting, there also appears to be various opinions regarding the necessity to duplicate such reports by conventional telephone to different divisions of the NRC.
In particular, Mr. Johnson has requested that all information reported on the dedicated phone be reported directly to him at his office; Mr. Conner has also requested that the more significant items so reported be recorted directly to him at his office. Additionally, it should be noted that if the threshold for reporting is low enough, certain items would be reported in Licensee Event Reoorts per the requirenents of our plant Technical Specifications. We fail to see why such duplicate reports have to be made; it would appear that the infomation reported on the dedicated phone could be disseminated internally within the NRC.
Based on the foregoing items, we perceive that the exicencies of the situation created by the Three Mile Island incident has resulted in some confusion regarding reporting requirements. He are concerned that if the reporting threshold is lowered too far, the resulting flood of reports would be distracting and time consuming to the plant operations personnel who have to make then and would dilute the real purpose of reportino the more significant events to the Comission. On the other hard, we realize the interest the Commissie...s in receivina reports of real significance and hope that guidance wi 3 provided accordingly.
t In the interim, until further guidance on the subject of reporting require-ments is provided by the Commission, we intend to lower the recorting threshold by reporting (by dedicated phone) any transient which causes the use of a plant Emercency Ocerating Procedure. Such a threshold will include the reporting of such relatively minor transients as a reactor trio and a drooped Control Element Asser.bly. The administrative controls necessary to suoport this comitment will be inplemented by August 24, 1979.
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,o IE BULLETIN 79-06B 4
ITEM 10F IE BULLETIN 79-06C REOUEST:
Document the action taken to implement the immediately effective portion of this bulletin.
RESPONSE
Upon receipt of the bulletin, the following actions were taken:
1.
E0P-5, Loss of Reactor Coolant, was revised to require the innediate shutd' wn of all RCP's upon the initiation of HPI caused by low reactor o
coolant systen pressure.
2.
The Nuclear Plant Engineer - Ooerations directed that three licensed operators shall remain in the Control Room at all times to implement this action.
We trust that the above information sufficiently resronds to your concerns in these areas.
Very truly youre mA-A. E. Lundva 1, Jr.
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Vice Presiden - Supoly AEL/ RED /dds Copies To:
J. A. Biddison, Esauire G. F. Trowbridae, Esauire E. L. Conner, Jr., NRC Director, Office of Inseection and Enforcement R. Sanaccre, American Nuclear Insurers
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