ML20098D686
| ML20098D686 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/22/1992 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9205290254 | |
| Download: ML20098D686 (4) | |
Text
_ _ _ _ _ _
^
GALTIMORE GAS AND ELECTRIC 1650 CALVERT CUFFS PARKY.AY
- LUSBY, MARYLAND 20S57-4702 GtoRot C CREtt Vict PntsiDENT NucLEAn Lutnos hiay 22,1W2
<..m e.o-....
U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk SUI 3]ECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2: Docket Nos. 50-317 & 50-318 NRC Region i Inspection Report Nos. 50-317N2-07 and 50 31892-07
[Echruary 16.1W2 to h1 arch 28.1992)
REFERENCE:
(a)
Appendix A (Notice of Violation) to NRC Region i Resident inspection Report Nos. 50-317N2-07 and 50-318S2-07 (February 16, 1992 to h! arch 28,1992), dated April 14,1992 Gentlemen:
In response to Reference (a), Attachments (1) and (2) are provided. As discussed with hir. Pete Wilson of the NRC Resident Staff, this response is provided within 30 days of our receipt of the referenced Notice of Violation rather than within 30 days of issuance as stated in the applicable inspection report.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Veiy truly yours,
{Y
/
c,
/t GCC/EPW/epv:!rej/bjd Attachtsents i !\\
}
1
/
I-e
']h 7[h
)t 9205290254 920522 PDR ADOCK 05000317 O
_,._ _ _ -.. _~_ - _ _ _ _ _.. _ -
- _._. _.m.
Document Control Desk
'May 22,1992
,Pa e2 g
c cc:
D. A. Brune, Esquire J. E. Silberg, Etquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R.1. McLean, DNR J. II. Walter, PSC 1
l I
t
?
a r
.2..
l 6ITACilMENT R IMPI.EMENTATION OF TEMPOR ARY MOlllFICATIONS WITilOUT POSRC_HINIIM l
l 1.
DESCRIPTION AND CAUSE OFTilE INENT On the morning of March 20,1992, temporary alterations were installed to disable the automatic initiation of the Containment Spray Actuation Signal (CSAS) and the Containment Isolation Signal (CIS). Contrary to the requirements of Technical Specifications (U) 6.5.1.7.d and 6.5.1.7.h, these changes were made without prior Plant Operations and Safety Review Committee (POSRC) review of a written saiety evaluation.
i l
Because certair accident conditions had been identified during an Electrical Distribution System l
Functional Inspection involving CSAS and CIS which might have caused Emergency Diesel Generator (EDO) overloading, all three EDGs were declared inoperable on March 19 and both Units were shutdown.
Following shutdown, Operations desired to remain in Mode 4 while reducing hydrogen gas concentrations in the reactor coolant. Since Unit I was entering a refueling outage, it was necessary to reduce hydrogen concentration to a safe level !c permit subsequent opening of the reactor coolant boundary. Ilowever, EDO operability was required to ternain in Mode 4. Since CSAS and CIS werc not required to be operable in mode 4 and prompt restoration of EDG operability was desired, the temporary alterations to remove these signals were made in accordance with the " Emergency or l
exigent conditions" provision of Calvert Cliffs instruction (CCI) 117. Temporary Modification l
Control.
The cause of this violation was an inadequate Calvert Cliffs Instruction. At the time of the event, CCI 117 permitted temporary modifications without prior POSRC review of a written safety evaluation, provided that an " emergency" or " exigent" condition existed. Because CCI 117 did not define " emergency" or " exigent" conditions, such conditions were interpreted to exist without realizing that a departure from TS requirements would occur when exercising this provision.
II.
ColtREUFIVE STEPS TAKEN AND RESUllrS ACillEVED CCI 117 was changed on March 27,1992 to prevent the implementation of temporary modifications without prior POSRC review except in conditions authorized by 10 CFR 50.54(x). This more stringent criteria will ensure that all future modifications are either reviewed by POSRC or
- implemented under the guidelines of 10 CFR 50.54(x).
I Ill CORRECTIVE STEPS _WillCil WILL llE TAKEN TO AVOID FURTilER VIOIATIONS No additional actions are required to prevent future incidents of this type.
IV.
DATE WilEN FUllCOMPLIANCE AClllEVED Full compliance was achieved later on March 20, 1992 when the POSRC reviewed and recommended approval of the temporary modifications and the associated safety evaluation after their implementation.
1
A ITACllMENTJ2)
.INAI)KQllATE COltRECTIVE ACTION TO CONTitOI,TitANSIENT M ATEltIAl, I.
- 1) ESC [tIPTION ANI) CAUSE OFTilE EVENT Prior to the restart of Calvert Cliffs Ur.it 1 in 1990 after an extended outage, the Plant General hianager convened a Startup Review Board (SUR11) to meet regularly and review issues of potential concern which might affect the safe restart of Unit 1.
As a result of one such concern, the SURB generated an open item to evaluate and implement actions to reduce the seismic threat posed by transient equipment. To address thi3 concern, in November 1990, the Mainten nce Superintendent published a hiaintenance Superintendent Guideline (MSG) on transient material and conducted training with maintenante pers';nnel. When SilRB closed this item in February 1991, it recommended that control of transient materials should be addressed by a site. wide Calvert Cliffs Instruction (CCI). Because of its lower priority relative to other tasks, the proposed CCI had not tren completed by April 1992, when this violation was cited.
Despite the issuance of the MSG ar'd the training of maintenance personnel, transient material storage deficiencies were still observed in recent months. The major cause of these continued discrepancies was a lack of enforcement of the existing MSG, inadequate communication of managene spectations to space owners, and an absence of detailed site wide requirements for the control or.
.ient material (such as will be contained in the site wide instruction).
II.
COHitECTIVE STEPh TAKEN ANI) RESUI!!'S AClllEVEI)
Nuclear Maintenance, Radiation Safety, Chemistry, and Operations personnel conducted a walkdown of their spaces to identify transient material deGeiencies and due to increased awareness of this issue, continue to identify problems as they occur, The transient material deGciencies identified by these groups have been, or are being, corrected.
Ill.
COllRECTIVE STEPS WillCli WillllE TAKEN TO AVOII) FUllTIIElt VIDI ATIONS The et,..
ment to create a site-wide instruction for this issue has been entered into the site action item tracking system to ensure its implementation by July 31, 1992. The new instruction will promulgate seguirements for the control of transient material to be utilized by plant personnel when conducting work and performing space inspections. As pait of the implementation process, training will be conducted with the appropriate organizations and supenision. in the interim, these requirements are being reemphasized to supenision.
'Althou;h this issue was not originally placed in the site tracking systems, the issue Report system, irmicmented last summer, provides a mechanism to capture and address future issues and proposed corrective actions which are identined by groups lic SURB.
d,
- 1) ATE WilEN RUI,1,COMPl> LANCE ACIIIEVEI)
Full compliance will be achieved on or before July 31,19? ' " hen t.1e new site-wide instruction for transient material control is implemented.
1
'