ML19332G217
| ML19332G217 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/15/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8912200334 | |
| Download: ML19332G217 (3) | |
Text
,Ji 5d.' 1 % f
- [-
4 e' A..
. ~
A
+
BALTIMORE a
GAS AND ELECTRIC CHARLES CENTER. P. O. BOX 1475 BALTIMOR E, MARYLAND 21203 GEORGE C, CREEL v cc pass.ocu, -
December _15,1989 :
HvCLc AR ENtmov -
(300 too-dess U.' S. Nuclear - Regu' latory Commission
' Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear ' Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & $0-318 Enforcement Conference at NRC-Region I
Headquarters on December 5.1989 Gentlemen:
' At the subject enforcement. conference we presented the basis for our decision to defer J he local leak rate : test (LLRT) for Containment Penetration No. 41 beyond the t
interval' required. by 10 CFR 50, Appendix J. We indicated that while the decision was conservative from the-standpoint of nuclear safety, neither our - decision nor-its basis were adequately communicated withi the Nuclear Regulatory Commission (NRC) immediately-prior to the. test's final due date of May 10, 1989.
L
- As we discussed at the enforcement conference, we have determined ' the following problems contributed to this event: (1) the Plant Manager lacked a clear understanding r
of -the specific' applicability of. the Appendix J test interval requirement in this u
case; (2) ' this was - due, in part, to the fact that internal communication between
. Licensing : and the Plant Manager was not clear, complete, or adequately maintained throughout ' the event; (3): communications between Baltimore Gas and Electric Company j
(BG&E) and the NRC Project Manager on the subject of possible relief from the r
regulatory requirement to L perform the test were only pursued ' informally; and (4)'
_d L,
communication,between BG&E =and the NRC Resident Inspectors regarding the continuing problems encountered in performing the test (i.e., difficulty completing the Spent Fuel Pool Cooling System -(SFPCS) piping weld repair) was not maintained between May 7 and E
- May 10,1989.
We are taking actions to minimize the potential for a recurrence of this event. BG&E is developing administrative procedures (in addition to the existing procedure for L
license amendments) which will establish the process for formally seeking regulatory p
relief in. situations where it is needed (e.g., exemptions per 50.12 and code relief per 50.55a). The guidance contained in these procedures will improve communication internally and with both the NRC Project Manager and the Resident inspectors.
' Communications will begin at the time a potential need for relief is identified, and will continue up to the point relief is formally requested and either received or denied.
8912200334 891215 A[
PDR ADOCK 05000317 i
Q PDC 0
1
- w 1
.- Document Control Desk December 15,1989 Page 2 The Licensing Unit will develop these procedures by March 31, 1990 and train licensing personnel on these procedures by April 30, 1990. Following this, Licensing will conduct general training on these procedures for key site personnel, including managers, supervisors, and other appropriate personnel. The training will familiarize these personnel with the types of regulatory relief available, what situations they are applicable to, the essential elements of an adequate relief request, the NRC review and approval process, and the consequences of not receiving regulatory relief. This training will improve our-overall awareness of various types of regulatory requirements, and the need to establish and maintain good communication with the NRC if. we encounter difficulty complying with a requirement.
In August of this year, the responsibility for coordinating local leak rate testing was shifted from the Primary Systems Engineering Unit to the new Surveillance Test Program.
The Surveillance Test Program is controlled by CCI-104 and is administered by a
- dedicated Site Surveillance Test Program Manager (SSTPM). The SSTPM has been trained on the requirements of 10 CFR 50 Appendix J and the fact that these requirements must be integrated into the plant surveillance test schedule. CCI-104 now includes a statement that the SSTPM should contact Licensing as soon as it is known that a LLRT may be postponed.
At the enforcement conference we also indicated that the reliability of the SFPCS piping needs improvement. Accordingly, we are performing an engineering analysis to identify the root cause of the piping failures. Preliminary analyses by our Materials Engineering and Analysis Unit indicate that the failures are being caused by high cycle fatigue cracking. This study is scheduled to be completed by February 28, 1990.
Assuming additional testing or data collection is not required, we expect to be prepared to discuss the results of the study and our preliminary corrective action plan by March 30, 1990.
In summary, we believe the above actions will result in improved communications with the NRC in situations where compliance with a regulatory requirement is either not practical or is considered to present a safety concern. For future cases, it is clearly our intention to seek relief openly and formally, and to either obtain this relief or comply with the requirement. With regard to LLRTs specifically, the controls established within the improved Surveillance Test Program will ensure that any future compliance problems relating to 10 CFR 50 Appendix J are promptly identified and resolved. Finally, the planned evaluation of the SFPCS piping failures should result in improvements in system reliability.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly vo s,
^
/
l s
GCC/BSM/bjd
,.. k 'l '
..,.3.-
-t b.-"
.../.
- '1 s Document Contrcl Desk.
- j<
L7 - December 15, 1989-.
Page 3 '
n:
icc:
- D. Ai Brune,; Esquire-l:
J.'
E.
Silberg, Esquire R. A.Capra NRC S. A.McNeil, NRC W. T. Russell, NRC f
- J. T. Wiggins, NRC l
J. E. Beall, NRC T.' Magette DNR -
1' l-l 6s 1
l n
I i
--y J.o i
i
.i j: '
(
f
,