ML19325D172
| ML19325D172 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/11/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8910190111 | |
| Download: ML19325D172 (5) | |
Text
c.
i.,
1
. e
'. 4 -
.,c i
' BALTI M ORE GAS"AND
,y
~'
CHARLES CENTER. P. O. BOX 1476
- BALTIMORE, MARYLAND 21203 -
1.
i
?
GroRoc C, CRect Vics Partictnr Nuctran Ewenov :
uoo ao-**$5
' October 11, 1989 t
1 i U. S. Nuclear. Regulatory Commission Washington, DC 20555 -
- ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear. Power Plant
' Unit Nos, I '& 2; Docket Nos. 50-317 & 50-318 Combined Insocetion Reoort Nos. 50-317/89-14:-50-318/89-14
REFERENCE:
(a) Letter from Mr. J. T. Wiggins (NRC) to Mr. G. C. Creel (BG&E),'
dated August 28, 1989, same - subject Gentlemen:
Reference (a) forwarded NRC ' Region I Combined Inspection Report 317/89-14; 318/89-14.
Appendix A to ' Reference ' (a) is a No: ice of Violation regarding 10 CFR Part 50, Appendix J, Sections III.D, Type B and C Local Leak Rate Tests (LLRT). Specifically, there - were H three instances-where the required interval between tests was - exceeded.
Enclosure (1) provides our response to the Notice of. Violation.
Should you have L any further, questions regarding this matter, we will be pleased to-discuss them with you.
Very truly yours,
.l 4
h i
I GCC/MDM/ dim
(
i t,
Enclosure
~
.4 a
- cc:
- D. A. Brune, Esquire.
Silberg, ' Esquire i
'J.
E.
L R. A.Capra, NRC a
S. A. McNeil, NRC W. T. Russell, NRC g gf V. L. Pritchett, NRC ifi
' T. Magette, DNR 4
8910190111 891011 i
PDR ADOCK 05000317 a
- i;-
2 -. - -
V n
s
{
7, d
ENCLOSURE (11 REPLY TO A NOTICE OF YlOLATION INSPECTION REPORT' 50-317/89-14; 50-318/89-14 l
PENETRATION NO. 41 1.
' DESCRIPTION AND CAUSL'"' TiiE EVENT The local-leak rate test ~ (LLRT) for Penetration No. 41 was initially scheduled mid-April. This was well in advance of the final ~ due date of May 10. Ilowever, during April,- we experienced two events involving inadvertent. breeches of the containment boundary while core alterations were being performed. In response to-those problems, the decision was made to delay maintenance activities and other activitiec that might jeopardize containment integrity, such as the LLRT on Penetration No. 41, until the core was off loaded. At the time, the core-was scheduled to be off-loaded well before the May 10 date.
By eativ~ May the core had not been removed, and the test, to meet Appendix J requirements, had to be performed before the final due date. Preparations to perform the test were made. Around May 2,1989, a cracked weld was discovered on the discharge piping of No. 12 spent fuel pool cooling pump. To perform the -
LLRT, Penetration No. 41 would need to be closed, isolating shutdown cooling.
With shutdown cooling isolated and problems existing with spent fuel pool cooling, the Plant ~ Manager became concerned about maintaining adequate core cooling capability while performing the test.
- On May 5,1989, we contacted Region I and NRR about the possibility of obtaining relief from the May 10 duc date. We were informed by the Resident inspector and the Project Manager that relief would not be possible.
Repairs continued on spent fuel pool cooling and on May 6 we informed the Resident - of our progress and our decision to complete the test by May 10. At that point, our schedule showed we would have both trains of spent fuel pool cooling in service before May 10, thereby allowing us to safely perform the test.
The' spent fuel pool cooling train was not returned to service by May 10. Conse-
'quently, the Plant Manager made a conservative decision, based on our concern over the reduction in decay heat removal capability that would be involved, not to isolate shutdown cooling and perform the test.
l-l 2.
CORRECTIVE STEPS TAKEN AND RESUI,TS ACIIIEVED l
The LLRT for Penetration No. 41 was performed on July 8,
1989, with satisfactory results. The test was conducted with shutdown cooling isolated, after Unit 2's core had been off-loaded.
L 3.
i q,
4!
ENCLOSURE (1)
REPLY :TO A NOTICE OF ' VIOLATION INSPECTION REPORT 50-317/89-14; 50-318/89-14 3.
CORRECTIVE STEPS WillCli WILL BE TAKEN TO AVOID FURTIIER
- VIOL ATIONS To minimize ~ the potential for the recurrence of this type of event, we will continue to schedule LLRTs as far in advance of the final due date as practicable. ' If= unforeseen hardware problems arise that affect this schedule, we will develop an action plan to address the situation, included in this plan will be consideration of the need for requesting a one-time schedular exemption from 10 CFR 50 Appendix J.
LLRT requirements pursuant to the provisions of 10 CFR 50.12.
4.
D' ATE WilEN FULL COMPLI ANCE WAS ACillEVED, The LLRT - for Penetration No. 41 was satisfactorily completed on July 8,1989.
PENETRATION NO._R 1.
DESCRIPTION-AND CAUSE OF Tile EVENT Penetratio'n No. 38 'is' the demineralized water make-up line to th'e service water system and was scheduled for an LLRT in April, well in advance of its final due date of May 24, 1989. The LLRT - for this penetration was initially delayed, as with. Penetration No. _ 41, for safety reasons related to the assurance of a containment boundary during core alterations.
When the test was finally attempted, several tube leaks were discovered in No. 22 Service Water Heat Exchanger. The leaks resulted in an increased makeup water flow through Penetration No. 38. Since No. 22 Service Water Eleat Exchanger was the only operable service water heat exchanger at the time, and make-up flow through Penetration No. 38 was crucial, we decided not to perform the LLRT
. until the leaks could be repaired.
.2.
CORRECTIVE STEPS TAKEN AND RESULTS ACIIIEVED The LLRT for Penetration No. 38 was performed on June 2,1989 with satisfactory results. The test was performed after No. 22 Service Water lient Exchanger was repaired.
3.
CORRECTIVE - STEPS WillCil WILL BE TAKEN TO AVOID FURTilER VIOLATIONS Our corrective action for Penetration No. 38 are the same as penetration No. 41..
1 1
'L ENCLOSURE-m 1
REPLY TO A NOTICE 'OF VIOLATION INSPECTION REPORT $0-317/89-14; 50-318/89-14 s
ih 4.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full L compliance was achieved when the LLRT-for Penetration No. 38 was
- satisfactorily; completed on June 2, 1989.
i
,\\
PENETR ATION - NO. 5A.
1, DESCRIPTION AND CAUSE OF EVENT Local ~ leak rate tests are performed by the Electrical and Control (E&C)
B maintenance shop, whereas, any physical work
(-
valves or flanged penetrations is l
performed by the Mechanical Maintenance Shop. Since she LLRT data must be gathered prior to=
any maintenance (to. collect as-found data),. 4his =
pre-maintenance' requirement must be placed in the mechanical maintenance order,: a fact the maintenance planner in this event was aware of but did not satisfy.
The. LLRT for Penetration No. 50 was scheduled for March 27, 1989. Maintenance L
was scheduled for the following day to remove the penetration flanges.
1 On March 27 (one' day ahead of schedule and before the LLRT had been performed),
the Mechanical. Maintenance Supervisor directed' removal' of the penetration flanges
.in preparation for ' plant air hook-up to the containment one day ahead of schedule. The maintenance order did not specify that a LLRT had to be L
performed prior to removing the flanges.
Failure. to include the LLRT in the maintenance order was an error on the part E
" of - the mechanical maintenance planner. Contributing to this error. was the fact j
B
' that the-planner's' work order checklist did not have a step that would alert the maintenance planner to consider the need for an LLRT prior to performing work.
7 2.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVFJ1 The penetration flanges were removed before the LLRT. could be performed.
Consequently, no corrective action exists which could recover the as-found data.
,s s
However, this penetration has a history of very low leakage.
p' L'
3,
, COR RECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS To prevent this situation from occurring in the future, several corrective. steps have been taken. Training on this incident was given to applicable mechanical craft, supervisors, and planners. The training stressed the interface between LLRTs and maintenance work. The mechanical maintenance planners now have a list of. Type B and C penetrations. The list and a new field on the planners' worksheet - are used to provide specific LLRT requirements in applicable maintenance packages.
+ y
r.7 q
~4',.
M~
ENCLOSURE (1)
REPLY TO - A NOTICE OF VIOLATION INSPECTION ' REPORT 50-317/89-14; 50-318/39-14 Our ' corrective actions have provided the maintenance planners with better tools -
to ensure that the planning and scheduling of maintenance potentially affecting LLRTs is: considered before meintenance is performed.
4, DATE WilEN FULL COhlPLIANCE WAS ACIIIEVED Full compliance with LLRT requirements cannot be achieved because the flanges were removed' prior to conducting the test. Training for maintenance personnel was completed on August. 29, 1989. The mair,tenance ' planners' worksheet was revised on July 1, 1989.
EXTENSION The original due date for this response was September 27, 1989. A two-week extension-was granted by Region I on September 26, 1989. The extension was a
requested to allow sufficient time to resolve comments received on the first l
internal draft, j
I l
4 N.