ML20117P904
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December 15, 1988 MEMORANDUM FOR:
Lowell E. Tripp, Chief Reactor Pojects Section No. 3A Division of Reactor Projects Region I FROM:
Jack E. Rosenthal, Chief Reactor Operations Analysis Branch j
Office for Analysis and Evaluation i
of Operational Data 1
SUBJECT:
EVALUATION OF LERS FOR CALVERT CLIFFS, UNITS 1 AND l
AEOD INPUT 'ID SALP REVIEW COVERING THE PERIOD I
FROM SEPTEMBER 1, 1987 TO NOVEMBER 30, 1988 In support of the ongoing SALP reviews, AEOD has reviewed the reports i
submitted by Baltimore Gas and Electric Co, Calvert Cliffs, Units 1 & 2.
Our review concentrated on the safety significance, causes and corrective actions associated with the events; as well as the i
completeness, clarity, understandability and adequacy of the event report contents.
The enclosure provides additional observations from our review of the LERs.
If you should have any questions regarding this report, please contact either myself or Stephen Stern of my staff.
Mr. Stern can be reached at FTS 492-4438.
Jack E. Roser. thal, Chief Reactor Operations Analysis Branch Office for Analysis and Evaluation of Operational Data
Enclosure:
As stated j
Wistribution:
Project Director NRR G. Lanik, AEOD SRI j
Central Files DCS ROAB R/F JRosenthal SStern MWilliams KBlack
!! Taylor OSP /'
R0k P:AEOD P:AEOD EOD SStern:md G
ik JRosenthal 22 6
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AROD INPUT TO SALP REVIEW FOR CALVERT CLIFFS. UNITS 1 & 2 l
Baltimore Gas and Electric Company submitted about 24 reports for l
Calvert Cliffs, Units 1 and.2, not including updates, in the assessment period from September 1987 to November 1988. Our review included the following LER nisabers:
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Calvert Cliffs, Unit 1:
87-013 to 87-015 88-001 to 88-011 l
l Calvert Cliffs, Unit 2:
87-008 to 87-009 i
88-001 to 88-008 h LER review follows the general instructions and procedures of NUREG-1022. The specific review criteria and our findings follow:
1.
Sinni m ant Onaratina Eventa One event at Calvert Cliffs was identified as a significant events by the AROD screening and review process in the assessment period.
On April 14, 1988, the licensee reported that various control valves
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associated with safety injection, containment isolation auxiliary L
feedwater and steam generator blowdown could fail in an emergency situation. h failure could occur if the pressure regulators for the instrument air system were to fail, allowing full instrument air pressure to pass to solenoids which vent the air supplies to the valves I
during an ESF actuation. Thus during an emergency, the full instrument I
air pressure could cause the solenoids to reverse position realigning I
the valves to a non-emergency position.' At the time Unit 1 was in Mode 5 and Unit 2 at full power.
h licensee identified the cause of this problem as diaphrass material in certain regulators which could degrade in adverse environmental conditions both in normal service but more likely in post-accident-l conditions. h licettsee estimates 20 valves in each unit were impacted. h licensee concluded that the required safety function for these valves could be fulfilled by means of compensatory actions. N licensee did not file an LER on this event.
In our opinion, this event impacted on the ability of multiple safety systems to operate in accident conditions and could have " prevented the fulfillment of the safety function of structures or systems..." (Section (2)(v) of 50.73).
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None of the events at Calvert Cliffs, Un'its 1 and 2 was identified as a i
potential Abnormal Occurrence during this reporting period.
3.
AROD Technical Study Raports a
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None of.the events at Calvert Cliffs, Unita 1 and 2 were considered l
sufficiently serious to merit an in-depth technical study by ABOD in j
this assesement period.
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.t Period Four Preliminary Notification of Event or Unusual Occurrence were issued for Calvert Cliffs, Unita 1 and 2 during the assessment period.
h ae events were :
PNO-I-87-102, November 5, 1987 (Unit 1); Licensee commenced shutdown as a result of degraded conditions in both steam-driven auxiliary feedwater pumps.
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PNO-I-87-118, December 21, 1987 (Unit 2); Reactor tripped on loss of load caused by opening of generator output breaker. b breaker opened due to a ground fault on the permanent masnst generator stator winding.
PNO-I-88-016, February 1,1988 (Unit 2); Fire in an=neiator panel, located in h cable spreading room, caused loss of all control room annuciators. All emergency systems remained functional during the event.
PHO-I-88-095, September 15, 1988 (Unit 1); Licensee. employee died from. apparent anoxia or drowning. h victim jumped into the condensate storage tank in an effort to assist a diver who had fallen from an internal ladder before donning his breathing apparatus.
PHO-I-87-118 was reported as LER 87-09 for Unit 2.
PHO-I-88-095 at Unit 1 involved an the death of an employee in a non-nuclear industrial accident, which by itself does not require filing an LER with & NRC.
N licensee submitted no LER for the February 1,1988 fire which caused loss of all control room annuciators (PNO-I-88-016) at Unit 2.
h fire occurred in the annuciator panel in h cable spreading room and burned for 10 minutes. h licensee declared an alert.
Section (2)(x) of 50.73 states that the licensee shall report "Any event that posed an actual threat to the safety of the nuclear plant or significantly hampered site personnel in the performance of duties necessary for the safe operation of the nuclear power plant..."
Although the licensee contends that all emergency systems remained
. functional, the issue is whether the absence of the an=riators hampered site personnel in the safe operation of & plant. Region I inspectors concluded that "... loss of annunciation did not significantly impair 'h ability of the control room staff to recognize
.and respond to changing plant conditions... inspector concluded that this event posed no real threat to the health and safety of the public." (Inspection Report Nos. 50-317/88-04 & 50-318/88-05, pg 3).
In our opinion a fire in the cable spreading room is of sufficient importance to require reporting as an LER.
An LER was not submitted for PHO-1-87-102, the November 5, 1987 shutdown of Unit 1 as a result of degraded conditions in both steam-driven auxiliary feedwater pumps. Reportability would not be required in this instance if the motor-driven auxiliary feedwater pump is operable and provides sufficient raA = dent capacity for the auxiliary feedwater systam.
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rRR Qimlity The LERs adequately described all the major aspects of the event, including all compon-.t or system failures that contributed to the event and the significant corrective actions taken or planned to prevent recurrence.
6.
Event Nimes We assessed 24 non-security events in this reporting period assigning one or more causes to each event. Our assessment of these events indicates:
- 13 involved administrative control deficiencies, including inadequate instructions, communications, or procedures.
- 11 involved maintenance errors.
- 9 involved random equisment failures.
- 5 involved errors by non-licensed personnel.
The number of LERs involving administrative control deficiencies is an area of concern. Administrative control deficiencies were involved in 8 out of 13 LERs in Unit 1, with most of these administrative control events occurring during a refueling outage in the Spring of 1988.
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