ML20141G236
| ML20141G236 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/15/1997 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-317-97-01, 50-317-97-1, 50-318-97-01, 50-318-97-1, NUDOCS 9705220224 | |
| Download: ML20141G236 (5) | |
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[ 'I Curntrs 11. Cut NE Baltimore Gas and Electrie Company i
%ce President Cahen Clitfs Nuclear Power Plant Nuclear Enero 1650 Cah en Clith Parkuay i
Lusby. Ntaryland 20657 410 495-4455 l
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i May 15,1997
(
U. S. Nuclear Regulatory Commission
,i Washington, DC 20555 i
f ATTENTION:
Document Control Desk j
l SUIUECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 j
Reclv to Insoection Reoort Nos. 50-317(318V97-01 l
REFERENCE:
(a)
Letter from L. T. Doer 0ein (NRC) to C. H. Cruse (BGE), dated April 15, 1997, NRC Region I Integrated Inspection Report Nos. 50-317/97-01 j
and 50-318/97-01 i
l In response to Reference (a), Attachment (1) details our response to the cover letter of the subject
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Nuclear Regulatory Commission Inspection Report.
l The subject inspection Report cover letter described a weakness in the conduct of plant operations.
I Specifically, to support on-line maintenance on the Unit I service water heat exchangers, the plant briefly exited the Technical Specification Action Statement for watertight doors to reset the Action fi Statement time. clock. The cover letter requested that we provide an assessment of this event and describe the ccrrective actions we have taken or planned.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
j t /,j 9705220224 970515 Very truly yours, PDR ADOCK 05000317
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G PDR m
CHC/CDS/bjd Attachment 220065 l
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Document Control Desk i
May 15.1997 Page 2' cc:
R. S. Fleishman, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC A. W. Dromerick, NRC R.1. McLean, DNR Director, Project Directorate I-1, NRC J. II. Walter, PSC i
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ATTACHMENT (1) 4 y
BRIEFLY EXITING A TECHNICAL SPECIFICATION ACTION STATEMENT.TO RESET THE 1
ACTION STATEMENT TIME CLOCK r
BACKGROUND I
Nuclear Regulatory Commission (NRC) Region i Integrated Inspection Report Nos. 50-317/97-01 and 50-318/97-01 describes an apparent weakness in the conduct of plant operations at Calvert Cliffs.
Specifically, during elective maintenance performed on the Unit 1 Service Water (SRW) heat exchangers i
to support project work scheduled for the upcoming Unit 1 Refueling Outage, the plant briefly exited the i
Technical Specification Action Statement for watertight doors to reset the Action Statement time clock.
The maintenance activity was planned and implemented such that a challenge to the Action Statement 1
time period was necessary. An NRC Inspector questioned this practice and was concerned that it j
demonstrated a poor regard for the Technical Specification requirement. The cover letter to Integrated i
inspection Report Nos. 50-317/97-01 and 50-318/97-01 requested that Baltimore Gas and Electric Company respond to this concern, describing our assessment of this practice and any corrective actions
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we have taken or planned.
1 EVENT DESCRIPTION Ouring the week of February 24 through March 1,1997, Temporary Alteration No. 1-96-0185 was implemented to support the demolition and replacement of the Unit 1 SRW heat exchangers scheduled for the Calvert Cliffs Unit 1 1998 Refueling Outage. The temporary alteration involved removing asbestos laden insulation and lead based paint from both Nos.11 and 12 SRW Heat Exchangers.
The request to begin the work came to the Work Control Center on the morning of February 24,1997.
The Shirt Supervisor authorized removing the ventilat:on system from service (per Operating Instruction (01)-15, Section 6.12.B., Initiating Emergency SRW Room Ventilation) during the work activity, to reduce the potential for exposure of personnel to hazardous substances. The Shift Supervisor also directed opening the double watertight doors into the SRW Pump Room to provide ventilation to the room. The Shift Supervisor was aware that opening watertight doors for maintenance was an accepted i
practice and that historically this Technical Specification Action Statement was interpreted to be met as long as the doors were clesed within the allowed outage time.
The Action Statement for Technical Specification 3.7.10, Watertight Doors, was entered, and the Shift Supervisor gave approval for installation of the temporary alteration to proceed at 0900 on February 24, 1997. The Action Statement requires that with the door open, restore the door to its closed position within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Following entry into the Action Statement the SRW Pump Room double watertight doors were opened and remained open for approximately 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> and 30 minutes. Approximately 5 minutes after the closing of the doors, they were reopened, thus meeting the literal requirements of the Technical Specification Action Statement. The doors remained open for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 50 minutes and were then closed. At 1720, on February 25, 1997, the doors were again opened for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 54 minutes and then cycled shut and reopened.
On February 26, 1997 an NRC Resident inspector questioned the practice of entering the Action Statement and allowing a waienight doors to remain open for the majority of the action time limit and then " resetting the clock" by briefly cycling the doors shut and then open again. Plant Management i
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1 ATTACllMENT (1)
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BRIEFLY EXITING A TECilNICAL SPECIFICATION ACTION STATEMENT TO RESET TIIE ACTION STATEMENT TIME CLOCK personnel met with the Resident Inspector to discuss the concern. Following the meeting, the Shift i
Supervisor wrote an issue Report and was directed by the General Supervisor-Nuclear Operations to not
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exceed greater than one-half of the watertight door Technical Specification Action Statement time limit to support continuing work on the SRW heat exchangers. These actions were implemented on February 27,1997.
ASSESSMENT OF ISSUE We have reviewed the practice of briefly exiting the watertight door Technical Specification Action Statement to reset the Action Statement time clock. - We have concluded that this practice was a poor practice that did not meet the intent of the watertight door Technical Specification.
We have concluded that the safety significance of briefly exiting the watertight door Technical Specification Action Statement to reset the time clock was low.
The Bases for Technical Specification 3/4.7.10 states that it is provided to ensure the protection of safety-related equipment from the effects of water or steam escaping from ruptured pipes or components in adjoining rooms. Any time
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the SRW Pump Room watertight doors are opened, a security watch must be established to shut the doors upon direction from the Control Room. During the time the watertight doors were open, a security watch was posted at the doors. All water and air hoses routed through the doors were required to have quick disconnects at the doors in case the doors needed to be closed quickly.
Although the above compensatory actions would have provided protection of the safety-related equipment in the room in most situations, a high energy line break near the open door could have prevented the security guard from closing the door. However, it is considered that a high energy line break of sufficient magnitude and/or location to prevent the security guard from completing this action was very unlikely.
The results of a recently completed review to identify and correct other potential poor practices in i
implementing Technical Specification requirements indicates that the practice of briefly exiting Technical Specification Action Statements and then reentering them to reset the Action Statement time clock was not wide spread at Calvert Cliffs.
Based on the above, we have concluded that the long standing practice of briefly closing and reopening watertight doors to reset the Action Statement time clock did not increase the likelihood of a plant event or significantly increase the potential consequences of most postulated plant events. Leaving watertight doors open for maintenance activities with a security guard at the door did present a potential increase in the consequences of a high energy line break event, but the likelihood of such an event is considered small.
CAUSAL FACTORS The brief closing and reopening of watertight doors to reset the Action Statement time clock was a long-standing practice at Calve t Cliffs. This practice arose because plant personnel viewed controlling the 2
ATTACHMENT (1)
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BRIEFLY EXITING A TECIINICAL SPECIFICATION ACTION STATEMENT TO RESET TIIE ACTION STATEMENT TIME CLOCK doors in this manner as an acceptable work practice that maintained the plant in a safe condition and in compliance with Technical Specification 3.7.10, Watertight Doors.
Maintenance Program procedure MN-1202, Conduct of Plant Work Control, requires a contingency plan when work activities may result in exceeding one-half of a Technical Specification allowed outage time.
In this case, we did not properly implement these controls because it was thought that they did not apply to the watertight doors.
CORRECTIVE ACTIONS TAKEN AND PLANNED An issue Report was prepared documenting the issue.
e On February 26, 1997 the General Supervisor-Nuclear Operations issued a Night Order to reemphasize that a contingency plan must be in place nor any planned maintenance activity that would exceed one half of the Action Statement time, including for watertight doors, as required by MN 1-202. It is no longer acceptable to shut waterticht donts for a brief time period to reset the Action Statemen' time clock. This Night Order emphasizes that all Technical Specification Action Statements are o be applied in the same fashion.
The Plant General Manager wrote a memorandum to all Site Supervisors concerning Technical e
Specification compliance. This memo stated that the practice of closing and then re-opening the watertight doors to reset the Action Statement time clock was completely unacceptable. The memo also emphasized that if a Technical Specification Action Statement has a time limit, it is to be respected and that practices of this sort involving multiple entries into Technical Specification Action Statements must not occur.
1 We have wnducted a review to identify other potential poor practices in implementing our Technical i
e Specifications. The results of this review indicate that the practice of briefly exiting Technical Specification Action Statements and then re-entering them to reset the Action Statement time clock was not wide spread at Calvert Cliffs.
A root cause analysis for this event is still underway. This root cause analysis is evaluating the safety significance, causal factors, and corrective actions for this event. The root cause analysis will also make recommendations for improvements. Appropriate additional corrective actions will be implemented based on the results of this root cause analysis.
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