ML19337B010
| ML19337B010 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/14/1980 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19337A991 | List: |
| References | |
| NUDOCS 8010010194 | |
| Download: ML19337B010 (3) | |
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B ALTIMORE G AS AND ELECTRIC COMPANY P.O. B O X 14 7 5 B ALTIM O R E. M A R YL AN D 21203 AnfM Jn E. LUNOVALL,Ja.
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- Sures, May 14, 1980 U.S. Nuclear Regulatory Commission Docket Nos.
50-317 Region I 50-318 631 Park Avenue License flos.
DPR-53 King of Prussia, PA 19406 DPR-69 ATTENTI0ft: Mr. Eldon J. Brunner, Chief Reactor Operation and Nuclear Support Branch Gentlemen:
This refers to your Inspection Report 50-317/80-01; 50-318/80-01, which transmitted items of apparent noncompliance with NRC requirements.
Enclosure (1) to this letter is a written statement in reply to the items noted in your letter of April 22, 1980.
Should you have further questions regarding this reply, we will be pleased to discuss them with you.
Very truly y urs, nu A. E. Lundvall r.
Vice President-Supply AEL/ RED /gla Enclosure 8310010
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ENCLOSURE (1)
REPLY TO NRC:
IE REGION I LETTER OF APRIL 22, 1980 APPENDIX A, NOTICE OF VIOLATION Item A On February 6,1980, NPE-0 Standing Instruction 80-1 was issued to require that whenever a diesel starts due to an emergency start signal (ESS),
before that diesel is shutdown, the signal reset must be verified locally at the Engineered Safety Features Cabinet.
Revision 12 to 01-21. Diesel Generators, has been issued to include a similar precaution in the " shutdown" section.
Item B The applicability of the reporting requirement set forth by Technical Specification 6.9.1.8.f to this situation was the subject of detailed discussi6ns between our staff, your resident insp2ctor and Mr. E. C. McCabe, Jr., of your staff.
It has been our practice in the past to make reports under this paragraph if the provisions of Technical Specification 3.0.3 were applicable. That is, if a personnel error or procedural inadequacy prevented an LC0 and/or associated " Action" requirement from being satisfied because of circumstances in excess of those addressed in the specifications, we consider this reporting requirement to apply.
This reporting philosophy was derived in part from the obvious logic used in writir.g the Technical Specification LC0/ Action Statements; each Action Stater..ent allows a limited degradation in redundancy below that assumed in the SAR. The SAR generally assumes that all redundant systems are operable prior to the time of the accident.
Then, at the time the accident is imposed, a single failure is presumed to occur which removes a certain portion of the redundant equipment from service. A known, pre-existing condition, such as a low pressure SI pump out of service for repair, does not constitute the single failure; the failure is presumed to occur at the time of the accident. By limiting the time any redundant piece of equipment or system can be out of service, the Action Statements of the Technical Specifications limit exposure to situations wherein an accident condition could occur and a presumed single failure plus pre-existing condition would render an entire safety function inoperable.
Such philosophy is rather straight-forward and can readily be applied to systems such as Safety Injection and Boric Acid. The AC power sources are more complex and require a more complex sequence of Action Statements.
The logic used to derive these Action Statements is explained in Regulatory Guide 1.93, Availability of Electric Power Sources. This guide states that the two hours allowed to restore at least one source of onsite power is considered to result in less risk than would be associated with an imediate shutdown. Such judgment was evidently made based on probabilistic analysis, similar to the probabilistic approach which allows any redundant components or system to be out of service for a limited time, even though such a pre-existing condition would not satisfy the single failure criteria applied in the SAR.
ENCLOSURE (1)
REPLY T0 flRC:
IE REGION I LETTER OF APRIL 22, 1980 APPENDIX A, NOTICE OF VIOLATI0fl j
i It is our understanding that the LC0/ Action Statements in the Technical Specifications provide an envelope in which continued plant operation does j
not jeopardize the basic probability assumptions made to support the SAR.
)
So long as the Action Statements are fulfilled, the operation of systems and equipment are within the overall assumptions made to protect the health and safety of the public. Therefore, we do not believe the event described by J
your report to have been reportable under Technical Specification 6.9.1.8.f and request that you reconsider the issuance of this item of noncompliance.
Item C Until the end of 1978, it had been our practice to assemble a summary of Technical Specification violations noted in NRC inspection reports and present this sumary to the POSRC on a periodic basis.
This summary included recommendations to prevent recurrence as they were made in our letters of reply to the inspection reports.
Since replies to the NRC inspection reports must generally (20 days), :.hese replies are not reviewed by the POSRC be submitted within a relatively short time from receipt of the report prior to their being sent.
The sumary reviews by the POSRC were made after the fact and could not alter or add to the actions committed to in the letters of reply and, as such, were of no real value.
After consideration of this situation early in 1979, it was noted that in most all cases the responsibilities of the POSRC as set forth in Technical Specification 6.5.1.6 literally requires a " review".
However, paragraph e (as stated in your Notice of Violation) does Mt require that a " review" i
be perfomed, it requires that "... the POSRC shall be responsible for investication of all violations of the Technical Specifications... ".
At this time, based on the 1 iteral statement of the specification, we detemined that it was not in fact necessary for the POSRC, as a body, to review the l
Technical Specification violations covered by NRC inspection reports and the corresponding letters of reply.
It is our opinion that the Chief Engineer, as Chaiman of the POSRC, does in fact discharge this responsibility (as an agent of the comittee) by directing the investigations to be perfomed and forwarding the eesults to the Manager - Electric Production Department and to the Chaiman - OSSRC, in the fom of letters of reply to NRC inspections.
Consequently, we request that you reconsider the issuance of this item of noncompliance.
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