ML20012B653
| ML20012B653 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/06/1990 |
| From: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| References | |
| EA-89-222, NUDOCS 9003160046 | |
| Download: ML20012B653 (14) | |
See also: IR 05000317/1989014
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MAR 66 W
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Docket Nos.: '50-317/50-318
EA No.:
89-222
Baltimore Gas a.nd Electric Company
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ATTN: Mr. George C. Creel
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Vice President
Nuclear Energy
,
-Calvert Cliffs Nuclear Power Plant
MD Rts 2 & 4
Post Office Box 1535
,
Lusby, Maryland 20657
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Gentlemen:.
Subject:- Enforcement Conference Summary
,
On December 5,1989, an Enforcement Conference was held in the Region I office,
to discuss your October 11, 1989 response to a Notice of Violation contained in
Combined Inspection Report Nos. 50-317/89-14 and 50-318/89-14
Specifically,
you were asked to address the circumstances involved in deferring the local
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leak rate- test of a containment penetration beyond its established interval.
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We have evaluated .the information you provided at the Enforcement Conference
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and in-your supplemental response dated December 15, 1989. After careful con-
sideration of all of the material, we conclude that no additional enforcement -
action is warranted. We will review the corrective actions you described in
your letter in a future inspection,
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In your presentation and subsequent letter, you stated that the decisions made
by the' Manager, . Calvert. C11f fs Nuclear Power Department were conservative and
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in the interest of safety. Although we agree that the. actions taken were not-
adverse to safety, we want to emphasize that it is not an acceptable practice,
except as specified in 10 CFR 50.54x, for licensees to take actions that are
. contrary to regulatory requirements without prior review and concurrence by the
NRC staff. We trust that you agree'with our position and that you will appro-
priately-communicate that position to members of your staff.-
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Your cooperation in this matter is appreciated.
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Sincerely,
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ORIGINAL SIGNED BY:
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William F. Kane, Director
Division of Reactor Projects
Enclosure:
Enforcement Conference Summary
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W. Lippold, General Supervisor, Technical Services Engineering
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T. Magette, Administrator, Nuclear Evaluations
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'J. Lemons,. Manager, Nuclear Outage Management
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R. Denton, Manager, Calvert Cliffs Nuclear Power Plant
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J. Walter, Engineering Division, Public Service Commission of Maryland
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K. Burger, Esquire, Maryland People's Counsel
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P. Birnie, Maryland Safe Energy Coalition
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Public Document Room (PDR)
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local Public Document Room (LPDR)
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Nuclear Safety Information Center (NSIC)
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State of Maryland (2)
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Region I Docket Room (with concurrences)
Management-Assistant, DRMA (w/o enc 1)
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W. Russell, RA
T. Martin, DRA
D. Holody, EC
W. Kane, DRP
J. Wiggins, DRP
J. Linville, DRP
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C. Cowgill, DRP'
O. Limroth, DRP
K. Lathrop, DRP
K. Abraham,.PA
M. Miller, SLO ~
J. McGrath, SAO
J. Dyer, EDO
J. Lieberman, OE
J. 'oldberg, 0GC
M. La11ahan, OCA
J. Partlow, NRR
R. Capra, NRR
D. Mcdonald, NRR
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Enforcement Conference Summary
- 1.
Purpose of Meeting
This Enforcement Conference was held to discuss an aspect of Baltimore Gas
and Electric's (BG&E) October 11, 1989 response to a Notice of Violation
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forwarded to it on August 28, 1989.
The specific violation involved a
local leak- rate test which was deferred beyond its due date on the shut-
down - cooling system suction penetration (penetration No. 41) and the
utility's response which indicated that a deliberate decision had been
made to defer performance of the test.
The utility was requested in a
November 13, 1989 letter, to address the basis used to determine that
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deferral of the test represented a conservative decision and to address
the process used to develop that basis and to implement the conclusions
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reached.
2.
Meeting Attendees
The Utility and NRC attendees at the meeting are shown in Attachment 1.
3.
-Utility Presentation
Messrs. George Creel and Lee Russell presented the utility's position on
the circumstances and chronology for the decision to defer the local leak
rate test on penetration 41. The presentation, shown in Attachment 2 to
-this report, is' consistent with the content of the utility's letter.
Basically, the. Plant Manager concluded that, in light of technical prob-
lems and concerns regarding the reliability of the spent fuel pool cooling
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system' piping, it was not prudent from' a - safety perspective to isolate
shutdown cooling for the test and rely on a single train of spent fuel
pool cooling for decay heat removal. The technical concern with the spent
fuel pool cooling system involved its susceptibility to high-cycle' fatigue
failure of-the welded pipe joints.
The t' ant Manager indicated that he was cognizant of Technical Specifica-
tior, mqvirements for local leak rate tests but was not sensitive to the
fact that these tests were also required under 10 CFR 50, Appendix J.
He
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also was not fully aware of the appropriate methods to be used to gain
' formal
relief from regulatory requirements, he would depend on the
utility's Licensing Unit for that type of support.
According to tt.e ~ Plant Manager,_ insufficient internal communications
adversely affected the ability of the Licensing Unit to contribute to the
solution to the test scheduling concern.
The utility further discussed
corrective actions taken as a result of its review of this issue. These
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actions included:
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Enforcement Conference Summary
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Improvements in internal and external communications.
2.
Improvements in the procedures used to process requests for regula-
tory relief.
3.
A Surveillance Test Program reorganization.
4.
Improvements in the reliability of the Spent Fuel Pool Cooling piping
system,
4.
NRC Response
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The NRC staff assessed the technical aspects of the decision to defer the
local leak rate test on . penetration No. 41 and concluded that the utility
had a reasonable technical basis for not completing the test until the
spent fuel pool cooling system was restored. However, the staff was con-
cerned regarding the sensitivity of senior plant managers regarding the
need for and the methods to be used to gain formal NRC relief from regula-
tory requirements.
Regarding the licensee's written response to the violation, the staff con-
cluded that it reasonably represented the facts as they occurred in.this
case.
' However, the staff found that the corrective actions that were presented
by the licensee went considerably beyond those provided in its written
response to the Notice of Violation. Consequently, the staff requested a
docketed submittal providing then supplemental corrective actions. The
licensee agreed to provide this supplemental response.
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ATTACHMENT 1
Enforcement Conference Attendees
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Baltimore Gas and Electric Company
G. Creel, Vice President - Nuclear Energy
S. Cowne, Licensing
G. Detter, Independent Safety Evaluation Unit
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B. Montgomery, Licensing
L.' Russell, Nuclear Power Department Manager
U.S. Nuclear Regulatory Commission
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B. Boger, Assistant Director for Region I, Office of Nuclear Reactor
Regulation (NRR)
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R. Capra, Director, Project Directorate I-1, NRR-
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R. Christopher, Enforcement Specialist, Region I ~(RI)
H.-Eichenholz, Senior Resident Inspector, Yankee Nuclear Power Station
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M. Hunemuller, Senior Engineer, Licensing Qualification, NRR
S. Hcrwitz, Public Affairs, RI
W. Kane, Director, Division of Reactor Projects (DRP)
D. Limroth, Project Engineer, DRP
R. Matakas, Office of Investigations, RI
T. Martin, Deputy Regional Administrator, RI
S. McNeil, Project Manager, NRR
W. Troskoski, Office of Enforcement
J. Wiggins, Chief, Reactor Projects Branch No. 1, DRP
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BALTIMORE
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Enforcement
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Conference
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December 5,1989
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NRC INSP$CTION REPORT 89-14/14L
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EVENT / VIOLATION
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Failure to conduct Local Leak Rate Testing on
Penetration 41 within required 2 Year and
28 Day Interval
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SLIDE 2.CH T
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MEETING AGENDA
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System Description-
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Basis for our Decision
Lessons-Learned
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CONTAINMENT
PE NETR ATION 41
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CHRONOLOGY
Nov 1988
Scheduler identifies need to obtain'LLRTJextension
Dec 15-
Licensing submits request for Tech Spec amendment to support 28
day extension
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Dec 21
Licensing submits request for Appendix J exemption
Jan 1989
NRR Project Manager requests additional data to support extension
request
Feb 17
Licensing submits requested supporting data
Mar 15
NRR Project Manager approves 28 day extension to Appendix J and
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associated Tech Spec amendment
Apr 30
Outage Coordinator recognizes that defueling may not be completed.
in time to support LLRT by May 10
May 1
- 12 Spent Fuel Pool Cooling piping weld crack discovered
May 4
Outage Coordinator requests that Licensing obtain regulatory
relief to permit deferring LLRT until after defueling
May 5-
Plant Manager
discusses
relief
with
Senior
Resident
Inspector and General Supervisor-Technical Services Engineering
Licensing contacts NRR Project Manager to discuss regulatory
relief
Nuclear Engineering Unit calculates heatup rates to assess impact
of performing LLRT
Licensing notifies Outage
Coordinator of
poor prospect
of
regulatory relief
Outage
Coordinator
discusses
schedule with
Plant
Manager.
Potential impact of SFP piping repairs noted.
Schedule revised
to perform LLRT prior to defueling and immediately after both
trains of SFP Cooling are fully operable
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Senior Resident Inspector contacts NRC Region Office to discuss
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discretionary enforcement relief
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CHRONOLOGY
May.6
Plant Manager discusses LLRT and SFP repairs with Senior Resident
Inspector and advises him that he' intends to do the test before
May 10
May 8-10
LLRT schedule slips daily as SFP weld repair difficulties are
encountered.
-LLRT schedule highlighted on Daily Management
Report
- May 10
LLRT deadline passes.
hydro
complete. Oil leak and discoloration discovered on #12 SFP Pump
May 15
Oil leak / discoloration resolved.
LLRT delayed for procedure
revision
' May 18
SFP vent piping leak discovered
May 19
LLRT procedure revision complete
Jun 2
SFP piping repaired.
- 12 SFP. Pump seal leak discovered
Jun 5
Seal leak-repaired
Jun 6
LLRT- pre-job brief identifies additional procedure deficiencies
-Jun 7
Leak reported on valve RV-469 which would prevent setting plant
conditions for LLRT
Scheduling Conference recommends deferring LLRT until
after
defueling (expected I week delay).
Operations concurs.
Senior
Resident Inspector informed
Jun 7-
Repeated delays encountered in defueling
-Jul 5
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LJul 5
Defueling completed
Jul 8
LLRT performed.
Results satisfactory
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BASIS FOR DECISION
Configuration while performing LLRT-
Possibility of Problems with LLRT and SFPC
Consequences of exceeding 200 F. in core
Consequences of not performing LLRT by
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May 10,1989
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LESSONS-LEARNED
Communications were inadeauate
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Internal
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Procedures for regulatory relief
Surveillance Test Program reorganization
Reliability of SFPC piping needs improvement
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