ML20199D860
| ML20199D860 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/17/1997 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-317-97-05, 50-317-97-5, 50-318-97-05, 50-318-97-5, NUDOCS 9711210029 | |
| Download: ML20199D860 (5) | |
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l Curotis 11. Cut >so Baltimore Oas and Elev.ric Company l
V,cv President Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkway Lusby, Maryland 20657 410 495 4455 November 17,1997 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Docum;nt Control Desk SUllJECT:
C alvert Cliffs Nuclear Power Plant Uni: Nos.1 & 2; Docket Nos. 50-317 & 50-318 NRC Region i Integrated Inspection Report Nos. 50-317/97-05 and 50-318/97-05 and Notice of Violation
REFERENCE:
(a)
Letter from Mr. L. T. Doerflein (NRC) to Mr. C. It Cruse (DGE), dated October 9, 1997, NRC Region I integrated Inspection Report Nos. 50-317/97-05 and 50-318/97-05 and Notice of Violation Please Ond attached our response to a Notice of Violation contained in Reference (a) concerning corrective actions to prevent recurrence of emergency lighting failures.
An extension to the 30-day response period was discussed with and approved by Mr. R. V. Crienjak, Nuclear Regulatory Commission on November 6,1997.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Vey truly yours, n C,YC f
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CilC/CDS/bjd
.'m ('m i 7a e1 Attachment ec:
R. S. Fleishman, Esquire
- 11. J. Miller, NRC J. E. Silberg Esquire Resident inspector, NRC Director, Project Directorate 1-1, NRC R.1. McLean, DNR A. W. Dromerick, NRC J.11. Walter, PSC
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L. T. Doer 0ein, NRC 9711210029 971117 7 PDR ADOCK 05000317' G
ATTACHMENT (1) 4-INSPECTION REPORT NOS. 50-317(318)/97-05-02 Technical Specification 6.4 requires, in part, that written procedures shall be establishedfor Fire Protection Program implementation. Nuclear Program Directive, SA-1, " Fire Protection Program."
(Section 6.1) states, in part, that testing, inspection, maintenance, non-conforming items, corrective actions, and administrative controlsfor the Calvert Chffs Fire Protection Program shall be controlled by the Quality Assurance Policyfor Calvert Chffs Nuclear Power Plant. The Quality Assurance Policy, Section 1B.16. " Corrective Action," states, in part, that controls have been estabihhed to ensure that issues are identified, documented, reviewed, and corrected Corrective actions are implemented by responsible personnel and may include immediate action, remedial action and/or actions to prevent recurrence.
Contrary to the above, as ofJuly 27,1997, BGE did not take action to identify and correct recurring problems with emergency lightingfixtures, including repeatedfailures of emeryncy lightingfixtures tested during 1996 and I997. Additionally, one cause of the lightingfalhares, that being a limited service
. hfe of the lighting batteries in high temperature environment, had not been evaluated to prevent repeated emergencylightingfailures, I.
REASON FOR TIIE VIOLATION Baltimore Gas and Electric Company accepts the violation.
Haltimore Gas and Electric Company chose to run components in the emergency lighting system to failure because we have not been able to identify specific criteria that could be used to predict failures of the batteries or electronic controls associated with this system. To compensate for the lower reliability associated with this strategy, we assign high priority to emergency light corrective maintenance. We have also structured the corrective maintenance on emergency lights such that corrective actions for failures may be initiated in the field as the failures are found during quarterly functional testing. These actions are intended to maximize availability of our emergency lights. We believe this is an acceptable strategy that does not constitute a reduction in safety because:
A.
It is commensurate with the safety significance and design of the system. The system is not contained within any core melt sequence, l
B.
The 4-8 percent failure rate we have experienced for the quarterly operational and aiming test is consistent with other piants we benchmarked.
C.
We maintain a reliable backup method for providing emergency nighting should the permanent l
emergency lighting system be unavailable.
I We have reviewed this strategy and believe it is reasonable strategy for maintaining our emergency lights. Ilowever, we also realize that the failure to establish specific goals and monitoring for reliability and availability could result in a less than aggressive follow through on some of the corrective actions identified. This, in turn, can contribute to higher failure.ates than we could otherwise ob".in. The failure to formalize our goals for this system also resulted in a difficulty in communicating with Nuclear Regulatory Commissior, inspectors on how and why the system is being maintained.
We agree the failure rates associated with eight-hour battery discharge tests (12-24 percent) were high.
Ilowever, even afler review we have not been able to identify any standard technologhs or isdustry practices that cost effectively reauce the failure rate of currently installed emergency lights. We should have more aggressively pursued a redundant emergency lighting system.
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ATTACllMENT (1)
INSPECTION REPORT NOS. 50-317(318)/97 05-02
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II. CQ11Rl'CILYlDilUS TIliT IIAVE HEM _IAKD AND Tile ILESULTS ACillEVED llaltimore Gas and Electric Company has been working to reduce the number of emergency lighting failures at Calvert Cliffs since 1993. Some actions were initiated from within Baltimorc Gas and Electric Company and many were identined as a result of coniacts with other plants concerning this issue.
Substantial progren has been made in addressing the performance of the emergency lighting systems at Calvert Cliffs since 1993. Among these have been improvements in our Preventive Maintenance Progrr.m. the addition of emergency lights where there was marginal lighting, and improvements to recond-keeping relative to individual e nergency light performance. Some of the specinc actions taken include:
A.
We assigned individtul equipment identification numbers to each emergency light in the plant and created an emergency lighting database on our NUCLEIS system. This database identifies and differentiates between lights that are required for Appendix R as well as tho,e required for personnel safety purposes. The database permits tr9cking of maintenance performed on individual emergency lights. This database has been available since January 1995. Prior to the implementation of this database, there was no easy way to track the age or maintenance history ofindividual emergency lights.
- 11. We performed Ocid walkdowns of all emergency lighting tmits to verify the units were properly located to support the steps contained within our A! ernate Safe Shutdown Procedure, t
Abnormal Operating Procedure,(AOP) 9. The walkdown team included an Operator familiar with AOP-9 steps to ensure me operator actions contained in this procedure were illuminated.
The Ocid walkdown did identify locations where additional emergency lighting units were recommended. These emergency lighting units were subsequently installed. In addition, niming marks were added to most of the lamp heads to assist in ensuring the lights were aligned to the optimal directions.
C.
An cipht-hour deep discharge test program was initiated in 1996. Tids test peiforms an eight-hour discharge test on a group of emeipency lights each quarter, such that all emergency lights are tested over a Ove year period. Approximately 17 lights are tested in this manner each quarter.
D.
The Preventive Maintenance Program for emergency lights has been improved. An Electrical Power Research Institute study en emergency lighting, which included suggested maintenance information, was reviewed. Information from the study was incorporated in 1995 where appropriate and cost effective. The Preventive Maintenance Program for emergency lighting was reassigned to a new work group which improved its performance.
E.
In order to return inoperable emergency lighting units to service as quickly as possible, we changed a procedure in 1995 (Fire Protection / Appendix R Compensatory Actions, SA-1-102) to require that Appendix R Emcrgency Light repairs be conducted as Priority 2 maintenance.
Priority 2 maintenance is high priority maintenance to address failed or deteriorating safety, reliability, or reactivity control equipment. Normally, Deld work for Priority 2 maintenance begins within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The preventive maintenance task has also been changed to allow on-the-spot corrective maintenance of emergency lighting units, with a subsequent issue Report to document what was fannd and what was done.
F.
The vendor has been brought on site several times to assist in reducing emergency light battery and charger problems. Ideas provided by the vendor have been instituted where prudent.
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ATTACilMENT (1) t INSPECTION REPORT NOS. 50-317(318)/97-05-02 G.
Some emergency light battery boxes were moved from high temperature environments to lower temperature environments, where possible. Many battery boxes could not be relocated to-eliminate this concern due to excessive voltage drop in some applications.' Appendix R i
separation criteria concerns also limit some location options.
- 11. Some emergency light battery boxes have also been relocated from mounting locations where high vibration was causing high failure rates. liigh vibration levels were determined to cause premature charger card failures in the emergency lighting units.
I.
Based on discussions with other plants, get cell type batteries were placed in several emergency lights located in high % t areas to address poor performance of wet cell type batteries in these environments and to address acid leakage problems that cause control circuit damage. The new batteries so far have performed better in high temperature environments. Subsequent battery replacements have beca using the new gel cell technology.
J.
Given industry wide concerns with emergency lighting units, we procured Dashlights and spare batteries and placed them in each of the pouches that are assigned to operators for use during an Appendix R post Gre shutdown using an AOP-9 procedure. The Dashlights are maintained on a quarterly bas!s.
K.
Blackout tests have been performed in many plant areas. Where we have performed blackout tests, we demonstrated adequate illumination exists.
'411. CORitEC1IVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS Our investigations indicate that corrective actions implemented to address emergency lighting failure rates were commensurate with the safety signi0cance of this system. To ensure the appropriate level of corrective action continues, we have added emergency lights to the Maintenance Rule scope for Calvert l
Cliffs. We are currently in the process of developing the performance criteria for emergency lights. The I
addition of emergency lights to the scope of the Maintenance Rule will result in a set of formalized goals and performance criteria for this system.
in evaluating our corrective actions, the replacement of lead-acid batteries with gel cell batteries for higher temperature applications was an area identified where we can be more aggressive without compromising resources required for more significant safety improvements. We plan to replace the wet cell lead acid batteries for emergency lights in the Turbine Building with new get cells by January 30, 1998. This change-out involves 110 emergency lights, or 220 batteries.
To address the problems associated with eight-hour battery capacity requirements we intend on pursuing a non standard solution. We have identiGed a cost effective way to improve our ability to ovide r
emergency lighting to operators during emergency conditions. We are currently in the process of implementing the' use of portable, hard-hat mounted emergency lights with a minimum eight-hour capacity as a redundant source of emergency lighting. Because the storage environment for these haid-hat lighting unit batteries can be controlled, they provide a reliable source of emergency lighting for operators to accomplish their actions under all accident conditions.
Our tests to date indicate this type of emergency lighting is very reliable
.,r periods of eight-hours or more. Equipment will be pre-staged and preventive maintenance will be performed to ensure these lights will be available when demanded. Use of the hard-hat lighting units will be implemented as a redundant I
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ATTACHMENT (1)
IL 'ECTION REPORT NOS. 50 317(318)/97-05-02 emergency lighting system capable of futulling the same functions as the existing system which we will continue to maintain using a run to failure strategy with specinc performance goals. This strategy augments our Appendix R implementation plan which the Nuclear Regulatory Cornmission reviewed and approved. Since this strategy augments our Appendix R implementation plan for emergency lighting, we will revise the Updated Final Safety Analysis Report to include this detail. 'This plan has been included here to ensure the Nuclear Regulatory Commission is aware of the direction we are taking.
IV. DATE WilEN FULL COMPLIANCE WILL BE ACillEVED The priority of our corrective actions for this issue have been increased. We are currently in full compliance.
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