ML20063F268
| ML20063F268 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/04/1994 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9402140214 | |
| Download: ML20063F268 (4) | |
Text
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A DALTIMORE GAS AND -
ELECTRIC 1650 CALVERT CLIFFS PARKWAY. LUSBY. MARYLAND 20657-4702 RoornT E, DENTON vice en=='
February 4,1994 NUCt1 AR cNE RGT (410)260 4499 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 & 50-318 Response to Notice of Violation 93-31-01
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REFERENCE:
(a)
Letter from M.. C. J. Cowgill (NRC) to Mr. R. E. Denton (BG&E),
l dated December 27,1993, NRC Region I Special Inspection Report Nos.50-317S3-31 and.50-318S3-31 l
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The suoject notice of violation cites an example of weak issue resolution concerning the implementation of follow-up corrective measures to address concerns surrounding the non-safer related makeup portion of our safety-related Service Water System. Reference (a) requested oc 6
provide our planned actions to improve our corrective action process. As detailed in Attachment (1),
we plan to follow through with implementation of ongoing actisitics to improve the results of our-corrective actions.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, E
m RED /CDS/bjd i
cc:
D. A. Brunc. Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R. I. McLean, DNR J. II. Walter, PSC 00004;3 9402140214 940204 i
PDR ADOCK 05000317 l
0 PDR q
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p A'ITACIIMENT m RESPONSE TO NOTICE Ok VIOLATION 93 31 01 ON CORRECTIVE ACTION PROCESS WEAK.NESSES Notice of Violation 50-317(318)/93-31-01 i dicates our corrective action process was not fully.
l effective in resolving issues concerning nousafety-related makeup water sources to our safety-related closed loop cooling water systems. Specifically, while our identification of the issue _was considered a strength, the issue was not resolved in a timely manner as required by 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions.
Baltimore Gas and Electric Company (BG&E) accepts the violation cited in NRC Inspection Report 93-31. We concur that the additional corrective actions taken to i.nprove service water (SRW) procedures subsequent to the September 29 instance of a high leakage rate are appropriate, and their earlier completion would have enhanced safety. Some of the actions taken did not meet BG&E management's expectations for timeliness, and some elements of the issue were not well communicated between site organizations.
i A.
DESCRIPTION AND CAUSE OF VIOLATION f
The facts regarding the manner in which BG&E handled the issue of closed loop cooling water systems are accurately described in the Inspection Report. We also concur with the report's conclusions with the following observations:
1.
In Section 5.2, the report concludes that the plant's operability criteria were not effectively implemented for this issue. Specifically,it states, "the elevated system leak rates represented a condition adverse to continued SRW System operation.
Inspectors assessed that the failure to identify the condition as an opernbility concern contributed to the lack of timeliness by BG&E in resoking the issue."
We agree that our assessment that the issue was not an operability concern, influenced our timeliness in responding to it.
We believe that decision was appropriate because, while elevated leakage rates had existed in the past, repairs had been promptly made. Excess SRW leakage did not exist either time the issue was raised, and therefore, the issue did not represent an immediate operability concern.
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2.
In Section 5.4, the report concludes that SRW Operating Instructions were inadequate prior to having the current leakage guidance and contingency plans in~
place.
We concur that definitive leak rate guidance should have been included earlier in the SRW Operating Instruction. We also agree that the contingency plans for SRW makeup alternatives should have been included in the procedures earlier. We believe, however, that the interim measures taken, including material staging and Operator training, were adequate interim corrective actions until the procedure changes were complete. We also note that while a contingency makeup capability from the safety-related Saltwater System is a prudent means of enhancing SRW System reliability, we do not consider it a requirement for system operability.
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NITACllMENT (I)
M RESPONSE TO NOTICE OF VIOLATION 93-31 01 ON CORRECTIVE ACTION PROCESS WEAKNESSES B.
CAUSES OF VIOLATION The causes of this violation are:
1.
The issue was initially assigned an inappropriately low priority. This decision was based on the low leakage at the time, but the high experience level of the initiator should have been a factor in its prioritization.
2.
Issue ownership was fragmented, making prioritization and oversight of resolution more difficult.
t 3.
Communication between organizations was not fully effective. Differences between t
Design Engineering and Plant Engineering's perspectives were not clearly identified.
These inconsistencies affected the actions taken by Nuclear Operations Support and l
by the Plant Operations Safety Review Committee.
4.
Management awareness of activity backlogs was incomplete.
C.
CORRECI'lVE ACTION TAKEN t
Baltimore Gas and Electric Company considers this instance an example illustrating areas in which our corrective action system should be improved. Management actions have been :nitiated to improve the corrective action system. These management actions encompass the generic concerns noted in this violation.
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Since the initiation of Generic Letter 91-18 in November 1991, we have undertaken a significant cffort to sensitize appropriate site personnel to the requirements for equipment operability. We have also developed procedures to facilitate the accurate and timely determination and resolution of significant operability concerns. These include multi-disciplinary and multi-layered reviews of issues for personnel safety, reportability, and operability concerns. We believe these processes are effective in causing operability issues that arise on site to be accurately and promptly identified, prioritized and dispositioned.
We have developed an action matrix summarizing the major concerns in our corrective action program. This matrix will allow us to focus on key areas where we can invest specific efforts to achieve improvements in this program. Responsible line supervisors have been tasked with addressing the identified prob! cms.
Some of the specific actions that have been implemented or are planned include:
1.
Proceduralizing the sole ownership of issue resolution. Issue Reports and Program -
Deficiency Reports are now assigned to an issue resolution sponsor who is responsible for acting as the focal point for assignment and resolution of allissue sub-tasks. The sponsor is responsible for ensuring all pertinent aspects of the issue are addressed and closin out the issue in a timely fashion.
2.
Development of specific expectations for corrective action adequacy to increase the assurance that generic implications of specific issues are addressed.
These expectations have been added to appropriate procedures and will be reinforced by enhanced supervisory and management review of corrective actions.
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ATTACIIMENT m RESPONSE TO NOTICE OF VIOIATION 93 31 01 ON CORRECTIVE ACTION PROCESS WEAKNESSES 3.
Development of methods to review the effectiveness of corrective actions that have been taken on issues. These methods include required reference to previous plant and industry events for higher priority root cause analyses.
4.
Development of key indicators to monitor the general health and effectiveness of the '
corrective action process. This data will be supplied to upper level management on a periodic basis. Information on this report tentatively includes recurring events, root cause analysis performance, issue status, status of corrective action quality indicators, and the age of all Program Deficiency Reports.
In addition to the generic actions being taken, the following specific corrective actions to achieve full compliance with 10 CFR Part 50, Appendix B, Criterion XVI for this issue, are complete:
1.
Contingency measures for using a temporary hose from the Saltwater System for emergency makeup to SRW have been incorporated into our Operating Instructions.
2.
Acceptance criteria have been established in the procedure for measuring system leak rates, including operability limits.
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