ML20059A535
| ML20059A535 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/21/1993 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9310260369 | |
| Download: ML20059A535 (3) | |
Text
__
. BALTIMORE GAS AND ELECTRIC i
1650 CALVERT CUFFS PARKWAY. LUSBY, MARYLAND 20657-4702 j
i
- I ROBERT E. DENTON vice earsiom October 21,1993 nucle AR ENCROY (4io) too 44ss U. S. Nuclear Regulatory Commission Washington,DC 20555 A'ITENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 j
Notice of Violation NRC Region 1 Combined Inspection Report
]
Nos. 50 31793-21 and 50-31893-21
REFERENCES:
(a)
Letter from Mr. J. P. Durr (NRC) to Mr. R. E. Denton (BG&E),
dated September 23, 1993, Notice of Violation NRC Region I Combined Inspection Nos. 50-317N3-21 and 50-31893-21 In response to Reference (a), please find Attachment (1) detailing our response to the cited violation concerning our design review process. As discussed in the attachment, we note that this deficiency was self-identified and that it did not result in equipment inoperability. We believe that upgrades in our design control processes implemented as part of our continuing improvement efforts will preclude similar violations from re::urring.
. Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
]
Very truly yours, j
N
{
RED /WDM/wdm/bjd k
Attachment
" l cc:
D. A. Brune, Esquire
- 4 J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC 1'. R. Wilson, NRC R. I. McIzan, DNR J. II. Walter, PSC
/
260m2 A
t 9310260369 971001 EN PDR ADOCK 05000317 N
,I l
1 G
PDR AG
ATTACIIMENT 0)
P REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-317(318)/93-21
)
IMPROPER SETTING OF SAFETY-RELATED TIMED RELAY 1.
DESCRIPTION OF VIOLATION.
Reference (a) states that on November 30,1992, measures were not established to assure design j
control for verifying or checking the adequacy of design, in that Facility Change Request (FCR) 90-29 was implemented without adequate design review, resulting in a safety-related Agastat i
timer for Auxiliary Feed Pump 13 being replaced and improperly set to 5 seconds instead of the i
previously established setting of 14.5 seconds. Reference (a) characterizes this as a violation of 10 CFR Part 50, Appendix B, Criterion IH.
11.
REASON FOR VIOLATION.
Two FCRs were involved in this incident. The first, FCR 90-0029, was initiated in 1990 to replace obsolete Agastat relays with a newer model. This FCR was not urgent; the affected relays were planned to be replaced over a long period as the equ:pment became available due to other maintenance. The second was FCR 92-0210, initiated in March 1992 to address an Emergency Diesel Generator operability concern. This FCR changed the setting for the 13 Auxiliary Feedwater 1
(AFW) pump LOCI sequencer time delay relay from 5 to 14.5 seconds. This FCR was urgent and was implemented on June 6,1992. It was not until November 1992 that the earlier relay replacement FCR was implemented on 13 AFW pump, incorrectly resetting the time delay back to its original i
5 second setting.
The violation occurred because unapproved, and therefore uncontrolled, relay setting sheets were issued with the earlier relay replacement FCR. The engineer preparing the package thought this was acceptable, when in fact it was not allowed by the controlling procedure. Subsequent review of the package did not identify the discrepancy, because review requirements in force at the time did not require thorough review of all parts of a package and because the relay setting sheets had no markings such as " preliminary." Had the relay setting sheets been properly approved, they would have been placed in the Relay Setting Book, the controlled location of all approved relay setpoints.
j The engineer preparing the second FCR would then have noted the need to update these earlier sheets when he reviewed this book.
i 111.
CORRECTIVE STEPS TAKEN AND RESUlli'S ACIIIEVED.
Upon discovery of the problem by a Baltimore Gas and Electric Company maintenance planner, 13 AFW pump was conservatively declared inoperable, the relay was returned to its correct setting of-14.5 seconds, and the pump was returned to operabic status. An engineering analysis determined that the Emergency Diesel Generator and 13 AFW pump would have remained operable even with the 5 second time delay relay setting. Facility Change Request 90-0029 was reviewed in its entirety to determine if any other affected relays were improperly set. No other discrepancies were found.
l i
IV.
CORRECTIVE ACTIONS WillCII Wil.L llE TAKEN TO AVOlD FURTilER VIOLATIONS.
Subsequent to the preparation of the original FCR, requirements for design review, qualification of responsible engineers, and control of design documentation have become much more stringent.
Procedural requirements for the control of relay setting sheets have been moved to their own 1
A1TACilN1ENT (1)
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-317(318)/93-21 IN1 PROPER SE'ITING OF SAFICIY-RElATED TIN 1ED RELAY procedure, which clearly identifies originator, review, and approval requirements for issuing relay setting sheets to the field. Additionally, new relay setting sheets now have separate signature blocks which make it obvious when a sheet is not yet fully reviewed and approved. This procedure is currently being revised to include specific requirements for the control and issue of relay setting sheets when they relate to plant design changes (FCRs). This revision is expected to be completed earlyin 1994.
V.
DATE WIIEN FULL CON 1PLIANCE WAS ACillEVED.
Full compliance was achieved on July 27,1993, upon completion of the engineering analysis and review of other affected relays described above.
e
?
I l
2
,~ -, -.,... -. - -,,
~
w-
'