ML20151L601
| ML20151L601 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/18/1988 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8804220093 | |
| Download: ML20151L601 (3) | |
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s B ALTIMOFtE i
OAS AND ELECTRIC i
CHARLES CENTER R O.90X 1475
- B ALTIMORE,MARvLAND 21203 r
JostPM A.TienNAN Vect Patt Disu t NW6 tan Centnef April 18,1988 t
U. S. Nuclear Regulatory CommisActi Washington, DC 20555 i
ATTENTION:
Document Control Desk I
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SUBJECT:
Calvert Cliffs Nuclear Power P12nt Unit Nos. I & 2; Docket Nos. 50 317 & $0-318 I
Recly to NRC Insocction Recort Nos. 50-317/88 OlLjo-318/01 l
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Gentlemen:
l The subject inspection report identified vae item of apparent non-compliarice with NRC requirements and two weaknesses. Enclosure (1) to this letter is our reply to the report.
In order to provide sufficient time for develop!ng.i response and to allow a thoroagh i
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management review, an extension to April 18, 1988, (eight days) was requested of and granted by NRC Region I.
Should you have any questions regarding this matter, we will be pleased in discuss them with you.
j Very truly yours, wtan i
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JAT/DLS/ dim
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Enclosure t
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D. A. Brune, Esquire j
i J. E.
Silberg, Esquire j
R. A.Capra. NRC l
1 S. A.McNeil NRC f
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1 W. T. Russell, NRC j
D. C.Trimble, NRC qt
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u ENCLOSURE (1)
REPLY to NRC INSPECTION REPORT 50-317/88-01; 50-318/88-01 APPARENT VIOLATION Two instances of apparent violation in the surveillance area, involving temporary changes to procedures and the lack of required reviews, were detailed in Appendix A.
In the first instance, a surveillance test procedure (STP) was deviated from without temporary changes being made to the procedure. A normally open valve in the recirculation path of an auxiliary feedwater pump was shut because an associated check valve was leaking. This step was taken with full concurrence of the Shift Supervisor (a licensed Senior Reactor Operator [SRO]) and under the recommendation of the system engineer. The intent of CCI-10lj (a review by two members of the plant staff, one of whom holds an SRO license) was in fact met. liowever, the procedure was not initialed.
The second case involved performing STP-O-65-2 (Quarterly Valve Operability Verification), with several temporary changes, prior to the required second review of these changes. These changes were required because a flow path described in the STP was not operable. In all cases the STP Cover Sheet reflected the changes. The intent of the STP, and therefore the operability of the equipment, was never compromised.
In each of these cases, operators did not adequately implement CCI-10lJ. The follwing steps have been taken to avoid further violations:
1.
The need for attention to detail in all procedural adherence, especially in changing procedures, was discussed in the GSO (General Supervisor-Operations) Notes and Instructions program.
2.
The first 1988 session of Licensed Requalification Training stressed the importance of adherence to the STPs and the accuracy required in reporting results.
3.
The Operations STP Coordinators have been made aware of the need for thorough and detailed reviews.
Results from these efforts thus far are positive. We are now in full compliance.
LICENSEE WEAKNESS - HOUSEKEEPING AND MATERIAL CONDITION The report detailed four areas; material adrift in the vicinity of safety-related buses and panels, scaffolding erected near safety-related equipment for long periods of time, l
general housekeeping in the Unit 2 east penetration room 5' elevation and the intake l
structure, and contamination in the ECCS pump rooms.
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Additional attention is being given to loose carts and other materials in the l
switchgear rooms and cable spreading rooms. We will minimize the time that such I
equipment is kept in these rooms and we have taken appropriate steps to secure such equipment to minimize hazards during potential seismic events, l 1
1 ENCLOSURE (1)
REPLY to NRC INSPECTION REPORT 50-317/88-01; 50-318/88-01 Scaffolding will be given more attention.
The Assistant General Supervisor Mechanical Modifications walks down all scaffold locations (excluding high-radiation areas) monthly to determine which scaffolding should remain in place due to job considerations. There are designated scaffold storage areas in the Auxiliary Building.
Greater emphasis is being placed on prompt return of scaffold materials to the designa-ted storage areas after use. The areas specifically identified in the inspection report as having loose scaffold materials have been corrected. Additional efforts are underway to identify areas where permanent platforms can replace scaffolding.
Considerable effort has been made to remove unnecessary material and to clean in the f
Unit 2 east penetration room 5 ft, elevation and the intake structure. Although additional and continuing efforts will be needed, these areas have improved.
i Contaminated areas in the ECCS pump rooms are an example of a situation where contamination control and generation of radwaste were weighed in view of operator access. Although routinely cleaned, the design of certain equipment makes it prone to slight leakage. The arrangement of step-off pads and contaminated area boundaries reflects concern for the need for expedient access while providing proper radiological controls.
LICENSEE WEAKNESS - INADEOUATE CONTROL OF TROUBLESHOOTING EFFORTS An evaluation is underway to examine our Electrical and Controls (E&C) troubleshooting practices and controls for adequacy. We are also examining troubleshooting guidelines used at other nuclear utilities. Our evaluation will be complete by July 1988. We then expect to develop our own E&C troubleshooting guideline.
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