ML20151F605
| ML20151F605 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/14/1988 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807270169 | |
| Download: ML20151F605 (4) | |
Text
4 B ALTIMORE 1
GAS AND l
ELECTRIC CHARLES CENTER R O. BOX 1475 BAL.TIMORE, MARYLAND 21203 JOSEPH A.TIERNAN vier PatsiotNT NucLEAn Ewrnov July 14, 1988 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 Reolv to NRC Insnestion Reoort Nos. 50-317/88-07: 50-318/88-08 Gentlemen:
The subject inspection report identified two apparent violations of NRC requirements.
Enclosure (1) to this letter is our reply to the Appendix A report, in order to provide a sufficient time for developing a response and to allow a thorough management review, an extension to July 16, 1988, was requested of and granted by NRC Region I in a telephone call with hir. L. E. Tripp (NRC). This extens'on made the response due 30 days after receipt of the report.
Shnuld you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, p+
JAT/Jh10/ dim Enclosure cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire R. A.Capra, NRC S. A.hicNeil, NRC l
W. T. Russell, NRC D. C. Trimble, NRC T. hiagette, DNR l
I l
8807270169 890714 PDR Ar)OCK 05000317 o
PNU, _
t ENCLOSURE (1)
REPLY to NRC INSPEC110N REPORT 50-317/88-07; 50-318/88-08 APPARENT VIOLATION No. I Appendix A to the report identified two apparent violations. The failure to submit the 1988 annual report detailing all failures and challenges tc the Pressurizer Power Operated Relief Valves (PORVs) or Safety Valves will be discussed first.
DD&.E Response
REFERENCE:
(a) Letter from hir. J. R. Lemons (BG&E) to Mr. W. T. Russell (NRC), dated July 1,
1987, Reports Required by Technical Specifications 6.9.1.4 and 6.9.1.5.b,c I.
Technical Specification 6.9.1.4 requires all annual reports covering the activities of the unit for the previous calendar year to be submitted prior to March 1 of each year. Technical Specification 6.9.1.5.c requires that an annual report shall be made documenting all failures and challenges to the PORVs and safety valves.
A.
Corrective Steos Taken and the Results Achieved A review of Licensee Event Reports (LER), Nuclear Plant Reliability Data, Nuclear Maintenance System Maintenance Orders and the Calvert Cliffs Instruction 118 Operations Reported Events Log was completed on June 13, 1988. The documentation of all failures and challenges to PORVs and safety valves for the period from January 1,
- 1987, to December 31, 1987, is as follows:
1.
On March 11, 1987, the Unit One Pressurizer Code Safety Valves (RV-200 and RV-201) opened outside of their setpoint tolerance during surveillance testing. This event is described in LER 50-317/87-06.
B.
Cerrective Steos Which Will be Taken to Avoid Further Violations The failure to submit the
- report, as required by the Technical Specifications, for the year of 1987 (due March 1,
1988) was due to insufficient formality and follow-up.
Responsibility and accountability have been assigned to formally address and resolve the reporting of failures and challenges to PORVs and safety valves.
C.
Date When Full Comoliance Will be Achieved BG&E will be in full compliance upon the submission of this response.
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ENCLOSURE (1)
REPLY to NRC INSPECrlON REPORT 50-317/88-07; 50-318/88-08 1
D.
Additional Discussion Detail 1. of the report noted BG&E had failed to submit the Annual Report for PORY and safety valve failures and challenges for the period of April 1,
1980, to Lecember 31, 1982. This report will be provided by September 19, 1988, as previously discossed with our NRC Project Mnaager. Detail 11 further noted the repost for 1984 - 1986 was not submitud. Reference (a) contains the report for this time period and states no failures or challenges to either the PORVs or safety valves were identified.
APPARENT VIOLATION NO. 2 The second apparent violation identified in Appendix A to the Inspection Report involved the fsilure to. properly approve temporary changes to written procedures covering strveillance and test activities.
BG&E Restwnse 11.
Technical Specification 6.8.1 seguires written procedures to be established, implemented and maintained covering surveillance and test activities of safety related equipment. Technical Specification 68.3 permits temporary changes to these procedures, if their intent is not alten ed, provided that prior to implementation of the changes they are approved by two members of plant management staff, at least one of wnom holds a Senior Reactor Operators lic ense on the unit affected.
A.
fau:!ctive Steos Taken and the Results Achieved We identified on Apri. 4, 1983, that an Instrurrent and Control Technician deviated from a Surveillance Test Procedur.
Containment Pressure (STP-M-529-1) without first processing the appropriate changes and obtaining the necessary approvals. The technicisn also fe.iled to document the procedural changes on the working copy of the procc<;iure.
The Plant Operations and Safety Review Comm'ltee subsequently reviewed
.hese changes and the failure to implement them properly. The entire i rocedure was then performed satisfactorily.
B.
Corrective Steos Which Will be Taker 1_1p_, Avow Further Violations BG&E ias determined this incident is isolated and that the review of procedtre changes prior to performance of safety-related surveillances and test activities is generally deliberate and proper. The technician who,
.... y ENCLOSURE (1)
REPLY to NRC INSPECTION REPORT 50-317/88-07; 50-318/88-08 failed to properly m::ke the chanke to STP-M-529-1 has been counselkd on the significance of his error and the proper course of action to take when temporary changes are required. Other In'trument and Control Maintenance Technicians have been informed of the details of this incident and its generic significance to proper plant operations, as specified in the Technical Specifications. Further, the proper and expected s:tions, to. be taken when temporary changes are made, were reviewed.
C.
Date When Full Comoliance Will be Achieved BG&E achieved full compliance when the proposed revision to STP-M-529-1 (Containment Pressure) was properly approved and the revised STP was satisfactorily performed.
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