ML20148H290

Forwards Response to IAEA Operational Safety Review Team Recommendations,Per NRC 871130 Request.Establishment of Nuclear Program Plan Objective for Detection of Deficiencies During Repetitive Maint Appropriate & Will Be Incorporated

ML20148H290
Person / Time
Site:	Calvert Cliffs
Issue date:	01/13/1988
From:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8801270189
Download: ML20148H290 (11)

Text

.

I I< ,*

B ALTIMORE GAS AND ELECTRIC CHARLES CENTER

• R O. BOX 1475 BALTIMORE, MARYLANC 21205 JoscPH A.TIERNAN Vet PatsIDENT NucLEAm ENEmOY January 13, 1988 U.S. th.1 clear Regulatory Comission Washirgton, DC 20555 Attention: Document Control Desk

Subject:

Calvert Cliffs lh.1 clear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 Resocase to IAEA OSARP Reccanondation

Reference:

(a) T. E. Murley (NRC) letter to J. A. Tiernan (IGE) dated November 30, 1987 Gentlemen:

Per your request, attached please fird our intentions regarding the recr,rnendations made by the International Atmic Durgy Agency's Operational Safety Revied Team. Per our agreement with your Mr. James G.

Partlow, only responses to those items where the OSART report used the word "r-rd" are incitded. 'Ihey are quoted frm the report for clarity.

Should you have any questions regarding our response, my point of contact is Mr. Steven E. Jones, Jr. (301-260-4107).

c Very truly y, curs,

' s W&- 1 JAT/SEJ/wvm Enclosure cc: Messrs: W.T. Russell, FRC T.E. Murley, NRC R.A. Capra, NRC J.G. Partlow, IRC S. A. i4cNoll, NRC T. Foley/D.C. Trirnble, NRC [

J.E. Silberg, Esquire D.A. Brune, Esquire r

00 8801270J89 880113 gi i ADOCK 7 DR

Document Control Dask January 13, 1988 Page 2 bec: R.F. Ash /R.C.L. Olson C.H. Cruse /P.E. Katz R.E. Denton/J.A. Mihalcik R.M. Douglass/S.E. Jones, Jr.

M. Gavrilas/E.I. Bauereis/T.N. Pritchett J.R. Intons/R.P. Heibel R.C. DeYoung W.J. Lippold/A.R. 'Ihornton F.J. Munno R.B. Pond /R.E. Cantrell L.B. Russell /J.T. Carroll C.M. Rice R.G. Staker W.R.1:orlacher, III M.E. Bowman /L.E. Salyards D.L. Shaw S.R. Cowne P.E. McGrane t

b

1-

[ .

i BG&E RESPONSE TO OSART RECOMMENDATIONS I. MANAGEMENT. ORGANIZATION AND ADMINISTRATION Recommendation (pg. 8)

"It is recommended that a reactor safety function be set up to closely monitor day-to-day activities and coordinate programmes related to plant safety."

Response

Monitoring day-to-day activities, which affect reactor safety is presently performed by plant supervision and management, by special committees such as the Plant Operations and Safety Review Committee and by the Quality Assurance Section. However, a study to determine the merits of establishing a full-time independent reactor safety group is in progress; a decision is expected during the first quarter of 1988.

II. TRAINING AED OUALIFICATION None III. OPERATIONS Recommendation (pg. 15)

"It is recommended that the noise level of the machinery be reduced and also that access of personnel to the control room be limited."

Response

Personnel access limitations, which significantly reduced the average number of people in the control room, were implemented during the OSART mission.

Additionally, steps are being taken to limit the number of PMs performed in the Control Room during the day t shift. Quieter computer printers had already been installed on Unit 2 and will be installed on Unit 1 this Spring.

Recommendation (pg. 16)

"It is recommended to c.id to the list of locked valves one isolation valve on each heat exchanger not protected by a safety valve."

1

Response

The majority of heat exchangers have installed thermal relief valve protection. However, to ensure protection of those heat exchangers not so equipped, the locked valve procedure will require an isolation valve to be left open providing a vent phth to a system relief valve. Similar provisions will be required when an unprotected heat exchanger is tagged out of service.

Recommendation (pg. 16)

"It is recommended that these modifications be incorporated in regular revisions of the documents (intervals not to exceed two years) ."

Response

Presently, procedures and reference documents are reviewed biennially. In the past, handwritten changes which remained valid were not necessarily incorporated into the typewritten text unless the procedure was revised for other reasons. However, in the future all handwritten changes will be incorporated into the procedure following its biennial review.

Recommendation (pg. 17)

"It is recommended that a duplicate be made for plant history after each annual verification by the General Supervisor-Operations."

Response

As recommended, the transient log records were transferred to plant history, and a process to ensure #

routine transfer of thermal evele information to plant history has been implemented.

Recommendation (pg. 17)

The list of abnormal procedures has been reviewed and the addition of some procedures is recommended to prepare for such abnormal events as the sticking open of pressurizer spray valves and restoring power after a partial loss of vital busses; 125 V(DC).

Response

A procedure addressing a stuck open pressurizer spray valve has been issued as part of our Alarm Manual.

Restoration of power to vital busses is a portion of the Abnormal Operating Procedure for loss of any electrical bus, which will be issued by the end of 1988.

1 l', .

Recommendation (pg. 17)

"It is recommended to complement EOP-O with operator guidance in emergency diagnostics."

Response

EOPs are written per an NRC approved guideline; a revision to that guideline, which incorporates diagnostic aids, has been submitted to the NRC for approval. Assuming NRC approval, the Calvert Cliffs Emergency Operating Procedures will be revised to incorporate those diagnostic aids in 1988.

Recommendation (pg. 17)

"It is also recommended to introduce increased setpoint margins for the parameters affected."

Response

The effect of adverse environmental conditions on vital containment instrumentation has been determined. We are certain that this instrumentation will continue to function properly. However, adverse conditions will effect some control room irlications. We will complece the documentation of the analysis of that effect by mid 1989, incl'uding the incorporation of any needed changes to the EOPs.

IV. MAINTENANCE Recommendation (pg. 19)

"It is therefore recommended that the link between leading and supporting MOs be modified and that work completion be redefined."

Response

The Nuclear Maintenance System will be modified to permit lead Maintenance Orders (MOs) to be transferred to plant history independent of the supporting MOs.

Recommendation (pg. 20)

"It is therefore recommended to develop the PM programme as a repetitive tasks programme with results integrated into maintenance history."

Response

A repetitive maintenance module for the Maintenance Information System will be developed and implemented by the end of 1989. The module will allow automatic scheduling, integration with plant history and trending  ;

for evaluation of preventive maintenance effectiveness.

As an interim measure, a database has been established for all PMs. Presently 450 PMs are being trended for effectiveness.

Recommendation (pg. 20)

"It is therefore recommended that the existing equipment history for essential equipment be transferred to a '

computerized management system."

Response

A study of alternatives for upgrading the plant history system is expected to be completed by the end of January 1988. As part of that study, the feasibility of transferring existing vital equipment history to a computerized system will be determined.

V. TECHNICAL SUPPORT I Recommendation (pg. 22)

"It is recommended that an overall coordinator be assigned to coordinate and advise the five surveillance coordinators."

l

Response

During 1988, BG&E will conduct an extensive evaluation of the surveillance program's effectiveness.

Organizational responsibilities will be included in the scope of that evaluation.

Recommendation (pg. 23)

"It is also recommended that an independent technical review of the operations surveillance test results be carried out by the responsible system engineer."

Response

By February 1988, system engineers will review all abnormal surveillance test results conducted by the Operations Section.

VI. TECHNICAL SUPPORT II l

Recommendation (pg. 27)  ;

"It is recommended that the operating organization develops and applies a comprehensive _ set of specific J operational safety indicators."

Response

As do all operating reactors in the United States, Calvert Cliffs tracks 79 indicators of operational safety and performance, reporting results quarterly to I the Institute of Nuclear Power Operation (INPO). We compare our results to that of the US industry as an indicator of deficient areas. We recognize that those ,

indicators do not necessarily correlate to operational l safety Therefore, as part of our "Severe Accident" work, we expect to complete the development of risk models for the plant. Once developed, we will use these models to determine if revision of our safety indicators is appropriate.

Recommendation (pg. 27)

"The development of a reliability model is recommended to evaluate the impact of the cumulative unavailability of safety related components and to establish overall reliability targets."

Response

During 1986, BG&E will begin tracking the reliability of the high pressure safety injection, auxiliary feedwater, and emergency AC power systems in conjunction with the INPO performanca and safety indicator program described in the preceeding response. Reliability targets in subsequent years will be based on a comparison of CCNPP and industry performance. Once the severe accident risk models are developed we will determine if they could be used to establish quantitative reliability targats based on the risk to the general public.

Recommendation (pg. 27)

"Although corrective actions are taken on a case-by-case basis, it is recommended that human error should be addressed as a generic issue."

'.~

Response

We will continue to improve the ability of supervisors to identify and correct problems which have a negative effect on the performance of our people. As an example, during 1987 managers and general supervisors were trained to use a formal approach to problem solving. In 1988, first line supervisors will be trained to identify and solve plant related problems. Each of these courses have direct application to identification and resolution of generic personnel performance problems.

Recommendation _(pg. 28)

"Since the main goal of all surveillance activities in nuclear power plants is to detect any latent deficiencies promptly before they cause an incident, it is recommended to define a corresponding objective, for example in Calvert Cliffs' Nuclear Program Plan."

Response

The establishment of a Nuclear Program Plan objective for detection of deficiencies during repetitive maintenance seems appropriate and will be incorporated.

The method used to measure this objective will be determined in conjunction with our reliability celitered maintenance program during 1988 and incorporated into the 1989 Nuclear Program Plan.

Recommendation (pg. 28)

"Comprehensiveness, detection thresholds, testing frequency and result trending are recommended to be adapted to plant specifics to make the surveillance activities as effective as reasonably achievable."

Response

! In the past, only degraded equipment performance l prompted evaluation of maintenance and surveillance test practices, and for the near term we will continue this approach. However, by the end of 1989, we expect all modules of the Maintenance Information lystem to be developed and lategrated. This will provide system i

engineers with a comprehensive analytical tool to apply

! to surveillance evaluations. At that time, we will adapt our surveillance and preventive maintenance I

programs to incorporate the results of periodic testing and corrective maintenance.

Recommendation (pg. 28)

"It is recommended to develop more guidance for personnel identifying and analyzing operating experience, to provide for independence of the evaluators from on-line activities and to establish overall coordination under a qualified individual."

Response

A set of questions will be developed to assist in the identification of events which have safety significance.

Once identified, those events are subjected to an in-depth analysis for which ample guidance exists.

However, that guidance is not as effective as desired in determining an event's root cause. Work is in progress, with the University of Maryland, to develop additional analysis aids to strengthen this aspect of our event analysis technique. Whether or not we establish an independent group to evaluate operating experience will depend on the outcome of the study referenced in our response to the recommendation on page 8.

VII. RADIATION PROTECTION Recommendation (pg. 30)

"Special efforts are recommended to reduce the number of these leaks, thereby reducing the associated contamination hazard."

Response

Leaking valve repair has and will continue to receive significant emphasis. In 1986 and 1987, we repacked 600 and 1000 valvec, respectively, with state-of-the-art Chesterton packing. In 1988, we plan to repack 1300 valves. Additionally, Radiation Safety and Maintenance conduct a joint inspection of the Auxiliary Building each quarter to identify any material deficiencies including the identification of leaks not already in the Nuclear Maintenance System.

Recommendation (pg. 31)

"It is recommended to change the layout of the sump drains so that a backflow of contaminated air is avoided."

Respcnse A multi-phased approach has been established to improve the sump drains in the Auxiliary Building. Extensive cleaning of the system was just completed.

Additionally, an indepth evaluation of the system is being conducted to improve drain flow and prevent backflow. The evaluation will include review of drain systems at other utilities and an evaluation of products now available which could prevent the cross flow of airborne contamination.

Recommendation (pg. 31)

"It is therefore recommer.ded that the air from the water surface above the fuel assembly worked on be withdrawn by a mobile ventilation unit connected to the fuel pool ventilation system."

Response

We do not agree with this recommendation. Use of mobile ventilation equipment would likely decrease visibility thereby increasing the risk of damaging otherwise sound fuel rods. Since no instance of sound rod breakage has yet occurred in the U.S., we don't feel that the potential for decreased exposure is worth the increased risk of damaging sound fuel rods.

Recommendation (pg. 31)

"Whenever a higher radiation level setpoint in a room is justified, it is recommended to change the alarm setpoint promptly (within a day)."

Response

The necessary changes to procedures will be made to incorporate this recommendation.

Recommendation (pg. 32)

"The installation of a continuous iodine monitor is therefore recommended in addition to the existing measuring device now in place."

(

Response

l t We will investigate available monitors to determine whether it's best to install an additional monitor, as recommended, or replace / modify the existing instrument.

l l

l

VIII. CHEMISTRY Recommendation (pg. 35)

"It is recommended that the configuration of the ventilation system for the hot lab and the counting room be modified to allow air to flow from the counting room to the hot lab."

Response

The ventilation system supplying the chemistry laboratories will be balanced following the completion of ducting modifications associated with the recently completed renovation of the entire access control area.

IX. EMERGENCY PLANNING AND PREPAREDNESS None 1

3 J

. . . , _ _ _ _