ML20042F577
| ML20042F577 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/04/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9005090093 | |
| Download: ML20042F577 (3) | |
Text
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p BALTIM O RE GAS AND ELECTRIC CHARLES CENTER. P. O. BOX 1475. BALTIMORE, MARYLAND 21203 GeoRot C. CRett w$$".'t7d"d May 4,1990 uon n.o-a.ss U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk SUDJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Inspection Report Nos. 50-317/90-80 and 50-318/90-80, Special Msintenance Team Insoection
REFERENCES:
(a) Letter from Mr. M. W.11odges (NRC) to Mr. G. C. Creel (BG&E),
dated April 4. 1990, same subject.
Gentlemen:
Enclosed as Attachment (1) is our response to the Notice of Violation contained within the subject inspection Report.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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GCC/CDS/db l
Attachment
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cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire l
R. A.Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC L. E. Nicholson, NRC R. McLean, DNR
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9005090093 900504 8
PDR ADOCK 05000317
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NITACIIMENT (1)
IBG&E RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-317/90-80; 50-318/90-80 Appendix A of NRC Inspec: ion Report 50-317/90-80; 50-318/90-80 is a Notice of Violation (NOV) of Technical Specification Surveillance Requirement 4.3.3.6. The NOV identifies a failure to fully satisfy the Technical Specification Surveillance Requirement for the Reactor Coolant System (RCS) Subcooled hiargin Monitor (SMM). Specifically, the NOV stated that the Surveillance Test Procedure (STP) for the SMM Channel Calibration did not fully satisfy the Technical Specification definition of CHANNEL CALIBRATION in that the STP did not include testing of the annunciator alarm portion of the channel.
Furthermore, it was noted that this was not an isolated incident and a total of five STP's had to be changed.
We have carefully reviewed the NOV relative to our interpretation of the broad Technical Specification definitions of CIIANNEL FUNCTIONAL TEST and CilANNEL CALIBRATION. It is our interpretation that the purpose of the CHANNEL FUNCTIONAL TEST and CilANNEL CALIBRATION is to verify that the instrumentation is capable of performing its intended safety function. The annunciator system at Calvert Cliffs was designed and constructed as non-safety-related. We have always treated annunciator alarms as enhancements to the safe operation of the Units. We do not consider them to be part of the primary success path to mitigate ' Design Basis Accidents or Transients as i
discussed in our Final Safety Analysis Report. We feel that the OPERABILITY of Technical Specification instrumentation is not generally tied to associated annunciator alarms. It is our interpretation that the OPERABILITY of Technical Specification instrumentation is tied to the ability of the instrumentation to perform its intended i
safety function.
4 in the specific case of the SMM, we feel that its primary safety function is to indicate rather than alarm. The SMM is only used during a post-accident scenario.
1 Emergency Operating Procedures direct operators to consult the SMM indication when appropriate after an accident. The SMM Channel Calibration STP a:lequately tests SMM indication at the Control Room panels.
Based on the above, while we agree that testing of annunciator alarms is a good operational practice, we believe that failure to verify the SMM annunciator alarm was i
not a violation of our Technical Specifications. Our corrective actions based on this philosophy are listed below, l.
Corrective Stens Which llave Been Taken and Results Achiend
'Ihe problem was discovered on February 15, 1990. We initiated a Non-Conformance s
Report (NCR) on February 16, 1990 to address the issue. We evaluated the issue
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to determine its safety significance. At the same time, we attempted to identify the intent of the Technical Specification definitions of CHANNEL CAllBRATION and CHANNEL FUNCTIONAL TEST. Our purpose was to proside a clearer definition of the specific requirement and its safety significance. We concluded that, in i
- general, failure to verify the alarm functions of Technical Specification circuitry does not affect the ability of the circuitry to perform its specified safety function and, therefore, does not affect its OPERABIL11 Y.
Only in l
several specific cases, when an alarm has a specified function in triggering an
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Emergency Operating Procedure (EOP) action, have we identified corrective actions we felt prudent to complete prior to returning the affected Unit to service. 1
ATTACHMENT (1) ae+e*
BG&E RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-317/90-80; 50-318/90-80 Based on the evaluation noted above, we developed an action plan consisting of a set of short term actions and long term actions to address the concern. This action plan forms the basis for all of our completed and scheduled corrective actions. Completed actions are identified below and scheduled actions are listed in Section 2.
a.
We have modified STP M-538-1 *Subcooled Margin Monitor Calibration", to include verification of the alarm function. This portion of the STP was then performed satisfactorily for Unit 1 on March 6,1990.
fr' m Control Room b.
We have identified all EOP steps that are triggered o
alarms in support of a safety function. Twenty three alarms were identified as being precursors for operator action - during EOPs. These alarms were identified as either; (1) tested by
- STP, Preventive Maintenance, or other operations surveillance; (2) non-safety significant; or (3) needing additional action, c.
We identified three alarms fnr each Unit that needed additional action.
For those three alarms on Unit I we have; (1) verified and documented that the alarm is functional, and; (2) changed the associated STP's to include alarm verification.
d.
For the three alarms requiring additional action for Unit 2,
the above actions described in (1) and (2) of item c. above will be completed prior to Unit 2 restart.
2.
Corrective Stens Which Will He Taken We plen to review alarm testing as part of the scope of our ongoing STP Improvement effort and make additional procedure changes, where appropriate. As part of this effort, we plan to identify the actual intent ot each Technical Specification Surveillance Requirement, and then to assure that our present method of performing the STP satisfies ' that intent. This effort is part of our Performance improvement Plan Action Plan for improving our Surveillance Test Program and ' will be completed in accordance with that schedule. The estimated completion date of the STP Improvement effort is currently the end of 1992.
3.
Date When Full Compliance Will Be Achieved We are currently in compliance with Technical Specification 3/4.3.3.6.
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