ML20012F551

Responds to NRC Re Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $100,000.Corrective Actions:Operating Procedures Changed to Prohibit Testing of ECCS When in Solid Water Condition

ML20012F551
Person / Time
Site:	Calvert Cliffs
Issue date:	04/06/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9004160118
Download: ML20012F551 (6)

Text

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f BALTIMORC 1

GAS AND ELECTRIC r

r CHARLES CENTER. P. O. BOX 1476. BALTIMORE, MARYLAND 21203 I

GCORGE C, CREtt V:ct Parsietut Nucktan CNtney nooesoa.ss April 6,1990 i

U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & $0-318 Notice of Violation - LTOP Controls i

REFERENCES:

(a) Letter from W. T. Russell (NRC) to G. C. Creel (BG&E), dated March 6, 1990, Notice of Violation and Proposed imposition of Civil Penalty - 5100,000 (b) Letter from D. G. Mcdonald (NRC) to G. C. Creel (BG&E), dated March 6,1990, Issuance of Amendments (TAC. No. 75562)

(c) Letter from G. C. Creel (BG&E) to Document Control Desk (NRC),

dated February 7,

1990, Description of Calvert Cliffs Low Temperature Overpressure Protection System (d) Letter from G. C. Creel (BG&E) to Document Control Desk (NRC),

i dated March 8,1990, Performance Improvement Plan - Revision 1 i

Gentlemen:

4 Baltimore Gas and Electric Company's reply to the Notice of Violation contained in Reference (a) is attached. Also attached is a check in the full amount of the civil penalty imposed by the Nuclear Regulatory Commission.

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'Decument Contrtl Desk April 6,1990 l

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

Very truly yours, i

l STATE OF MARYLAND et/kb nu>t kV'

/t I hereby cer ify that on the

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, be re me, the i

subyctiber,t[a Notary Public of the State of Malyland in and for

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, personally appeared George C. Creel, being duly sworn, and states that he is OVice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, I

information, and belief; and that he was authorized to provide the response on behalf of said Corporation.

WITNESS my lland and Notarial Seal:

M e /II u u /t

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Notar/ Public 8

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My Commission Expires:

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GCC/ PSF /bjd Attachment i

cc:

D. A. Brune, Esquire J. E.

Silberg, Esquire l,

R. A.Capra, NRC D. G. Mcdonald, Jr., NRC W. T. Russell, NRC L. E. Nicholson, NRC T. Magette, DNR l

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ENCL.OSURE f1)

REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 89-31/32 i

1.

VIOLATION OF 10CFR 50. APPENDIX B. CRITERlON Ill fDESIGN CONTROL)

The Notice of Violation described in Appendix A of Reference. (a) indicates Baltimore Gas and Electric Company (BG&E) failed to establish adequate measures to assure that the design basis criteria for the Low Temperature Overpressure Protection (LTOP) system was implemented. Specifically, BG&E failed to : (a) i prohibit testing of the Emergency Core Cooling System with solid water conditions, (b) fully analyze the power-operated relief valve discharge piping, (c) provide audible alarms to both pressure transmitters PT-103 and PT-103-1, (d) perform the staged disabling of the HPSI pumps, (e) develop procedures to prohibit the startup of the shutdown cooling system when steam generator temperature exceeds 220 F, and (f) lock shut the HPSI header isolation valves during water solid conditions.

A.

Admission or Denial of the Allened Violation The violation occurred as stated.

D.

Reasons for the Violation Two main causes contributed to this event. First, there was insufficient attention to detail and a lack of adequate self-verification in the initial implementation of LTOP controls. Second, there was insufficient control of the procedure change process. The regulatory basis for the LTOP procedural commitments was not captured, and as a result, some commitments were lost during the ongoing procedure revision process. These fall within the category of insufficient monitoring, followup, and trending identified in the Calvert Cliffs' Performance Improvement Plan.

C.

Corrective Steos that Have Been Taken and Results Achieved The following corrective actions have been taken for Unit 1.

Similar actions will be taken for Unit 2 to bring it into compliance with its appropriate LTOP controls.

1.

The Operating Procedures have been changed to prohibit testing of the Emergency Core Cooling System when in a solid water condition and the associated Surveillance Test Procedures will be changed prior to their use. Such tests had previously been prevented by supervisory judgement.

2.

The power operated relief valve discharge piping has been analyzed for liquid discharge. The pipe can handle a liquid discharge without a loss of function. No modifications were required as a result of this analysis.

3.

Pressure transmitters PT-103 and PT-103-1 are now alarmed through the plant computer.

A pressure transient (increasing) will cause an alarm to annunciate in the Control Room. Procedures require that the t

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I ENCLGiURE (1) l REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 39-31/32 i

plant computer not be intentionally removed from service while the plant is water solid.

l 4.

The IIPSI pumps are now disabled by procedure in accordance with the license amendment approved by the NRC on March 6,1990 (Reference (b)).

0 5.

It is impractical to continue to cool the RCS to 220 F using the steam generators alone. A safety evaluation (10 CFR 50.59) has documented that it is not an unreviewed safety question to use s

l shutdown cooling to assist the steam generators in an RCS cooldown.

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We informed NRC of this deviation in Reference (c).

6.

The HPSI header is effectively isolated as a source of high pressure mass addition by procedure when the RCS is in a solid water condition. A safety evaluation was performed to show that the t

protection afforded by having all three llPSI pump breakers racked out is equivalent to locking shut the 8' loop MOVs, or the 2 ' header isolation MOVs, or the 3 HPSI pump discharge valves.

D.

Corrective Stens That Will Be Taken to Avoid Further Violations The causes of this violation were consistent with those identified in 1

developing the Performance Improvement Plan (Reference (d)). Several sections of the Performance Improvement Plant (PIP) contain actions designed to address the root causes identified here. The PIP presently establishes firm management expectations for the control of future commitments through two mechanisms. Personnel Performance Objectives have l

been established under PIP Action Plan 2.2.1 using goals and priorities established by the Nuclear Program Plan. Additionally, a computerized Commitment Management System (CMS) is being implemented under PIP Action Plan 2.5.1.

Accountability for satisfying NRC and other commitments is I

achieved by monitoring the closeout process using CMS and the Performance i

Objectives.

E.

Date When Full Comoliance Will be Achieved l

The corrective actions described in Section C have already been taken for l

Unit

1. Corrective actions will be taken, as necessary, to bring Unit 2 into compliance with appropriate LTOP restraints, before the reactor l

coolant system is sealed up. The long term corrective actions are part of i

an ongoing process. Improvements made through PIP will continue to be monitored using the PIP verification process, l

11.

YlOLATION OF 10CFR 50. APPENDIX B. CRITERION XVI (CORRECTIVE ACTION) l The Notice of Violation described in Appendix A of Reference (a) indicates that i

BG&E failed to establish measures. to assure that conditions adverse to quality...

i EhiCLOSURE (1)

REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 89-31/32 such as deviations and deficiencies, are promptly identified and corrected, a

Specifically, BG&E failed to adequately identify and correctly evaluate LTOP deficiencies determined as follows: (a) the re-analysis of LTOP for 12 EFPY l

revealed that LTOP was potentially inadequate, however, no further evaluation of f

LTOP deficiencies or initiation of corrective actions occurred at the time; (b) an NRC inspection report identified that not all LTOP commitments were met, l

however, timely investigation and corrective actions were not taken; (c) a re analysis of LTOP for 16 EFPY revealed that LTOP was potentially inadequate, however, no further evaluation or corrective action was initiated.

A.

Admission or Denial of the Allened Violation The violation occurred as stated.

B.

Reasons for the Violation The root causes of this violation are insufficient monitoring and followup and insufficient issue discovery. The identified deficiencies were not captured or tracked by Nonconformance Report (NCR) or other action tracking systems. Additionally, ~ supervisory involvement and understanding of the issue was inse ficient to ensure proper prioritization and safety r

assessment. There existed a lack of a questioning attitude.

Existing controls were assumed to be safe. Discrepancies between actual and FSAR/SER controls were seen as administrative deficiencies in the reference which should be corrected when convenient. When reviewing future

controls, insufficient attention was given to evaluating potential l

implications for current safety.

I C.

Corrective Steos That Have Been Taken and Results Achieved The use of NCRs has been substantially improved to ensure capture and review of deficiencies such as those involved in this instance.

Procedures have been established and training has been conducted to ensure l

non-compliance with design or licensing documents is promptly reported on NCRs. NCRs have been issued for the identified deficiencies. The plant organization has been revised to provide additional supervision and resources to those areas where performance was deficient. Accountability of supervisors for appropriate safety assessment and proper prioritization has been reinforced. These management measures have significantly improved control of plant activities. They will continue to be monitored under the PIP verification program.

A Commitment implementation Assessment project was developed to assess BG&Es historical ability to manage regulatory commitments. The project concluded that BG&E has identified, implemented, and maintained commitments made to the NRC that are important to the safe operation at Calvert Cliffs.

';.I-ENCLOSURE fI)

REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 89-31/32 D.

Corrective Steor that Will Be Taken to Avoid Further Violation The PIP. has been modified to include a new action plan 2,5.2, Regulatory Commitment Managemcat Process. This Action Plan will define the process and organizational responsibilities used by BG&E for managing regulatory commitments, Guidance on commitment identification criteria,

tracking, closure

criteria, closure package maintenance, computerization, and verification will be provided. The conduct of a comprehensive and long-term licensing commitment review effort,. will also be addressed through this action plan,

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E.

Date When Full Comollance Will Be Achieved The Regulatory Commitment Management project is under development.

Additional details and an implementation schedule will be provided to the NRC by April 30, 1990.

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