ML20006E303

Responds to Violations Noted in Insp Repts 50-317/89-23 & 50-318/89-23.Corrective Actions:Commitment Mgt Sys in Place to Track Commitments Site Wide & Ensure Changes to Emergency Procedures Made in Timely Manner

ML20006E303
Person / Time
Site:	Calvert Cliffs
Issue date:	02/09/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9002220558
Download: ML20006E303 (3)

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• BALTIMORE i . GAS AND

(%ELECTRI CHARLES CENTER D.C. BOX 1476. BALTIMORE, MARYLAND 21203 Gromot C. Cntti Vict PReseptm, February 9,1990 NWCat AR rNtRev (300 #90+ eats r U. S. Nuclear Regulatory Commission Washington, DC 20555

(

L ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant l Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Combined Insnection Reoort Nos. 50-317/89-23: $0-318/89-23

REFERENCES:

(a) Letter from Mr. J. T. Wiggins (NRC) to Mr. G. C. Creel (BG&E),

dated January 10, 1990, same subject Gentlemen:

Reference (a) forwarded NRC Region I Combined inspection Report .317/89-23; 318/89-23.

Appendix A to Reference (a) is - a Notice of Violation regarding 10 CFR Part 50, Appendix B, Criterlon XVI, prompt -identification and- correction of conditions adverse to quality. Specifically, plant emergency procedures were not modified to incorporate proper void control requirements for natural circulation cooldown situations, in a timely manner. Enclosure (1) provides our response to the Notice of Violation.

Should you have any further questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, ,

/

1 GCC/MDM/db

l. Enclosure ec: D. A. Brune, Esquire f l

J. E. Silberg, Esquire R. A.Capra, NRC 6yfl8I D. G. Mcdonald, Jr., NRC W. T. Russell, NRC l-J. E. Beall, NRC #)I '

T. Magette, DNR ,

~ I 90022205D3 900209 PDR ADOCK050%7{}

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ENCLOSURE (1)

REPLY TO A NOTICE OF YlOLATION INSPECTION REPORT 50-317/89-23: 50-318/89-23

1. DESCRIPTION AND CAUSE OF Tile EVENT On May 5,1981, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 81-21, Natural Circulation Cooldown. Generic Letter 81-21 requested Licensees provide confirmation that a controlled natural circulation cooldown from operating conditions to cold shutdown conditions, conducted in accordance with our procedures, would not result in reactor vessel voiding. Our response to the Generic ' Letter was subrnitted on November 13, 1981. Our response stated we had revised Emergency Operating Procedure-12,

• Loss of Reactor Coolant Flow / Natural Circulation" to incorporate guidelines established by the Combustion Engineering Owner's Group (CEOG) and included in CEN- 152, " Combustion Engineering Emergency Procedures Guidelines". At the time of our submittal, CEN-152 was still under review by the NRC.

On July 8,1981, the NRC issued the Safety Evaluation Report for our response to the Generic Letter. Although the NRC staff did not review our procedures associated with natural circulation cooldown, they did state that "... upon acceptable implementation of the NRC-approved Combustion Engineering Emergency Procedure Guidelines, the licensee's procedures will be adequate to perform a safe natural circulation cooldown."

During early 1988, the NRC Senior Resident inspector at Calvert Cliffs performed Temporary Instruction 2515/86, " Inspection of Licensee's Actions Taken to implement Generic Letter No. 81-21, Natural Circulation Cooldown " The inspector noted a portion of CEN-152 had been revised to provide guidance for void elimination any time voiding jeopardizes or threatens RCS heat removal via natural circulation. The inspector also reviewed several Calvert Cliffs emergency procedures to see if the new guidance had been incorporated. The procedures had not been changed at that point, due to our decision to wait and make changes to the whole set of emergency procedures once CEN-152, Revision 3 was approved in its entirety. We did commit to modifying the applicable emergency procedures to reflect the approved CEN- 152, Revision 3 guidance regarding actions required to be taken when void formation jeopardizes or threatens RCS heat removal via natural circulation cooldown, in July of 1989, an NRC Resident inspector conducted a review of actions we had taken associated with this generic activity. The inspector noted the emergency procedures had not yet been changed to refleet the guidance for void elimination in CEN-) 52, Revision 3. On July 25, 1989, we committed to incorporate the guidance into our procedures by September 1, 1989. The changes to Abnormal l

Operating Procedure (AOP)-3F were made on August 31, 1989. The changes to the applicable Emergency Operating Procedures (EOPs) were approved on September 18, 1989.

The September 1,1989 date was not met due to a failure to adequately track the commitment we made to change the procedures. Additionally, sufficient attention to detail and management oversight were not provided.

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. .c ENCLOSURE O)

REPLY 'ID A NOTICE OF VIOLATION INSPECTION REPORT $0-317/89 50-318/89-23

11. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED On September 18, 1989, changes to the following EOPs for both Unit I and 2 were made:

o EOP-3, " Total Loss- of All Feedwater" o EOP-4, " Excess Steam Demand' o EOP-5, ' Loss of Coolant Accident" f o EOP-6, ' Steam Generator Tube Rupture"  !

o EOP-7, " Station Blackout" The procedures were modified to incorporate the guidance of CEN-152, Revision 3 by replacing the statement, 'E voiding inhibits heat removal. TjjEM reduce with voiding threatens heat removal or depressurization, THEN

..." 'E ,

reduce ...".

On August 31, 1989, AOP-3F was changed from, "E voiding inhibits heat i removal, IJEN reduce...* to 'E voiding jeopardizes heat removal, THEN reduce ..." . The changes to the EOPs and AOP-3F provide for operator action before heat removal is lost.

We feel these changes to our emergency procedures are adequate. Although the '

procedures were changed, an analysis performed in April 1989 determined that void formation in the reactor vessel upper head will not interfere with the cooldown.

Therefore, it is not necessary to provide further explicit guidance to operators in this area. Operator training for the procedure changes was satisfactory. ,

i 111. CORRECTIVE STEPS WillCil WILL BE TAKEN TO AVOID FURTilER VIOLATIONS L A Commitment Management System is now in place to track commitments site wide. .'

! This system is used to closely monitor the status of commitments rnade at Calvert Cliffs and ensure a high priority is placed on completing commitments on time.

To ensure important changes are made to emergency procedures in a timely manner, l l

the complement of personnel in the Procedure Development and Modifications Acceptance Unit has been significantly increased. We are proceeding to fill these new positions.

IV. DATE WilEN FULL COMPLI ANCE WAS ACIHEVED i The changes to the EOPs were approved on September 18, 1989. The change to AOP-3F was approved on August 31, 1989.

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