ML20205D182
| ML20205D182 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/19/1988 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| EA-88-202, NUDOCS 8810270072 | |
| Download: ML20205D182 (8) | |
Text
.
,~
8 S ALTIMORE GAS AND (Y
ELECTRIC CHARLES CENTER P. O. BOX 1475
- BALTIMORE. MARYLAND 21203 JostpH A.TstnNAN vice PassiotN1 NucLten Eeesmov October 19, 1988 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
J. Lieberman, Esquire Director, Office of Enforcement i
SUDJECT:
Calvert Cliffs Nuclear Power Plant
{
Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 i
Recly to a Notice of Violation. EA 88-202
[
R EFERENCE:
(a) Letter from Mr. W. T. Russell (NRC) to Mr. J. A. Tiernan (BG&E),
dated September 20, 1988, Notice o t' Violation and Proposed Imposition of Civil Penalties (NRC Inspection Report No.
50-317/88-17; 50-318/88-17)
Gentlemen:
Pursuant to the provisions of 10 CFR 2.201, Attachment (a) is our reply to the f
j violations delineated in Reference (a). Also, please find enclosed payment in the sum i
of 5150,000 for the referenced civil penalty (BGAE Check No. 1272567).
1 P
re.0,e d
f4 i
3 881027007:
'h O
$0R MDCN $$$
f g p),, f ggg gg a
kir. J. Lieberman October 19, 1988 Par.e 2 l
t Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, YW STATE OF MARYLAND g
g TO WIT :
LOlljtEo il CJlAK[>
( e I hereby certify that on the _ / N day of [O?fJded
, 19[> /zu(C
. before me, the supscriber, a Notary Public of the State of Maryland in and for
/
/ LuAL
, personally appeared Joseph A. Tiernan, being duly sworn, and states that he (A Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.
b
[
WITNESS my lland and Notarial Seal:
6 Notary Public U
My Commission Expires:
(d,,, / / Q14 4
6
' Date JAT/GLH/ dim Attachments cc:
D. A. lirune, Esquire J.
E.
Silberg, Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC D. C. Trimble/V. L. Pritchett, NRC T. Magette, DNR
I A'ITACHMEPfr (A) l REPI,Y TO A NOTICE OF VIOLATION EA 88-202 i
I f
VIOLATION NO.
1:
EMERGENCY DIFRFL GENERATOR EVENT 1.
Admission or Denial of the Allened Violation i
The violation occurred as stated.
2.
Reasons for the Violation The Violation occurred for the following reasons:
o Communication Breakdown As a result of the difficulty of paralleling the emergency diesel generator (EDG) onto the Engineered Safety Features Hus during a surveillance test, i
the Shift Supervisor (SS) decided to place the voltage regulator in the Manual (MAN) mode during the required post-start one-hour loaded run. The SS had intended that the voltage regulator would be returned to the Automatic (AUTO) mode at the completion of the test and believed his intention was understood by the Control Room Supervisor (CRS). The CRS then directed the Control Room Operator (CRO) to perform the one hour run.
Ilowever, the CRO had understood that the voltage regulator AUTO mode was inoperative and, therefore, left the voltage regulator in MAN. The CRO noted this in his log.
l l
o Lack of Adequate Follow-up The SS CRS, and the CRO did not discuss the voltage regulator problem after the completion of the surveillance test.
i o
Failure to Process a l'rocedure Change i
Administrative controls require that a formal change is written when an i
approved procedure is deviated from in a non emergency situation, This was l
not done. A formal change would have documented a step-by-step procedure to go into and recover from the unusual operation.
f 1
l I
l
.i.
e ATTACHMEN'T (A)
REPLY 'ID A NOTICE OF VIOLATION
' EA 33-202 '
I o
No Specific Guidance or Training i
There was no specific guidance provided in technical manuals, procedures, system descriptions, or training materials that discussed the question of EDG operability when the voltage
- gulator is placed in the MAN mode.
Since the main generator is often operated in the MAN mode, the operators were not concerned by the EDG voltage regulator being left in the MAN
- mode, j
j 3.
Corrective Steos That linve Been Taken and the Results Achieved After discovering that the voltage regulator was left in the MAN mode during surveillance testing, the switch was immediately returned to the AUTO mode and i
the EDG was determined to be operable. Subsequently, an evaluation was performed to determine what effect the voltage regulator being in MAN mode had on EDG operability. The following corrective actions have been taken as a result:
o The Operating Instructions have been modified to specifically state that the EDG is inoperable whenever the voltage regulator is not in AUTO mode, o
The Operating Instructions have also been modified to eliminate the test of the voltage regulator in MAN mode.
o Shift Supervisor, Reactor Operator (RO), and Senior Reactor Operator (SRO) licensed individuals that were involved in this event have been counseled regarding requirements for procedure adherence and control.
These individuals have also reviewed all appropriate controls and procedures used to ensure these requirements. This review has included the procedure for making temporary changes to Surveillance Test Procedures.
o The switch position for each EDG voltage regulator will be serified to be in the AUTO mode, unless otherwise authorized, at least once during each shift.
o Operator training for RO and SRO licensed individuals has been changed to incorporate training on the function and operation of the EDG voltage regulator in both MAN and AUTO modes. Techniques required for EDG operation in parallel with offsite power have also been included, o
The SS is now required to review the Control Room Operators' log during shift turnover.
4.
Corrective Steps That Will be Taken to Asold Further Violations Further correctise steps are currently in progress or under evaluation and include the following:
2
A*hrACHMENT (A) i REPLY '1T) A NOTICE OF VIOLATION EA 88-202 i
o Various methods for controlling the position of each EDG voltage regulator are being evaluated. As a minimum, the switch positions will be verified each shift, as discussed in Section 3.
Should the evaluation determine that these switches warrant an alarm
- function, the switch position i
verification at each shift will be deleted once the alarm function is operable.
I o
We will evaluate the MAN mode of operation of all controllers which could affect plant safety to determine if MAN operation could degrade plant safety.
4 o
All plant personnel will be counseled regarding requirements for procedure adherence and control.
Perso'inel will also be required to review appropriate controls and procedures appropriate to their job function to i
ensure these requirements.
i Date When Full Comoliance Was Achieved I
4 1
We were in compliance with the applicable requirements of Section 3/4.8.1.1 of i
I the Technical Specifications for the items cited in your Notice of Violation on i
June 6,1988.
l All the above actions will be completed by December 31, 1988, i
1
[
VIOLATION NO._1
[
MMCLEAR INSTRUMENT / DELTA T POWER EVENT 1.
Admission or Denial of Allered Violation f
I i
l The violation occurred as stated.
4 l
2.
Reason for Violation j
i The violation occurred for the following reasons:
i o
l' allure to l'ollow Procedure l
The CRO did not follow established procedures when adjusting the Delta T power potentiometer.
t i
l i
1 i
j l j
_.2-
_ _, -.. ~ __,.
___-__._._2.._,
~ _ _
1 e.
A*ITACHMENT (A)
REPLY TO A NOTICE OF VIOLATION EA 88-202 o
Communication Breakdown A contributing factor to the violation was ineffective communication i
between the organizations responsible for core physics and nuclear f
instrumentation and the operators. The operators did not appreciate the magnitude of the effect the low leakage core would have on the nuclear i
instrumentation.
Additionally, operators failed to inform Nuclear i
Engineering that there was a significant variation in. power level readings l
l and that the computer calorimetric power calculation was not functioning.
l 3.
Corrective Actions Taken and Results Achieved i
l Power level was confirmed after reactor power was stabilized at 30% Indicated
]
power. After verifying that the power level was actually 44%, all four channels of the Delta T power were immedistely adjusted to 44% and the operators began to reduce power to 30%. This action returned Reactor Protection System (RPS) high level trip setpoints to their correct levels. An evaluation was subsequently
)
performed to determine what effect the incorrect power indication had on the RPS.
]
The results of this analysis showed that our design basis safety analyses bound the consequences of this event. As a result of this event, the following corrective actions have been taken j
o The Escalation to Power Test Procedure (PSTP-3) has been revised to include I
l steps to check six indications of core power at 5% power increments from l
turbine parallel, approximately 15%, to 85% power. These six indications must be discussed with the CRS and agreement reached that core power is accurately known, prior to another 5% increase in power. Additional indications of power such as, megawatts-electric and feedwater flow are i
also monitored to check for consistency with the power indicators. A l
further check of core power is made at 30% indicated power. The indicated
)l power is compared with the computer calculated calorimetric power, or if the computer point is not assilable, the calorimetric calculation is j
p< rformed using Operating Instruction-30. This procedure step requires at 1
least a one-hour hold at 30% power. Power escalation cannot proceed until the power lesel is verified at 30% power.
(
o The Escalation to Power Test Procedure (PSTP-3) now requires a pre-shift i
briefing prior to escalation to power given by Nuclear Engineering Unit i
engineers to the operators. These briefings will: (1) continue until the completion of 85% power testing, (2) include a review of the testing j
performed durina the previous shift. (3) include a review of the power 1
levels and testing to be achiesed during the oncoming shift, and (4) include a discussion of any different operating conditions which might occur as a result of the reload core design, i
i I
i i
I I
4
NITACHMENT (A)
REPLY TO A NOTICE OF VIOLATION EA 84-202 o
Shift Supervisor, SRO, and RO licensed individuals that were involved in this event have been counseled regarding requirements for procedure adherence and control.
These individuals have also reviewed all appropriate controls and procedures used to ensure these requirements.
4.
Corrective Steos that Will be Taken to Avoid Further Violations Further corrective steps are currently in progress or under evaluation and include the following:
o Instruction will be provided on the accuracy and reliability of power indications at various power levels and the use of special test exceptions.
This information has been included in the current class of operator requalification
- training, initial operator training, and systems engineer training.
The training will be complete for these groups by December 31, 1988.
o An evaluation has been conducted to determine how accurate the Delta T power calibration potentiometer setpoints are below 90% power. Notes will be added to the Units I and 2 setpoint sheets which indicate what the setpoint tolerances are for various power levels. This will prevent recurrence of a significant potentiometer setpoint change by providing additional guidance to the operators. This change will be complete by October 31, 1988, o
As discussed previously, all personnel will be counseled regarding procedure adherence and control.
5.
Date When Comoliance Achieved RPS trip setpoints were returned to their proper settings at 2200 on July 4,1988.
j f
All the above actions will be completed by December 31, 1988.
l 5
ATTACHMENT (A)
REPLY TO A NOTICE OF VIOLATION EA 88-202 i
i i
GENERAL COMMENT
S j
On August 8, 1988, an enforcement conference was held to discuss the violations and
[
j their causes. Questions were raised regarding procedural compliance, communications, and resolution of potential safety problems. We shared our general concerns and j
1 expectations for these and other issues, and presented several corrective actions.
We have taken and will continue to take strong, aggressive action to ensure the public safety and the continued safe operation of the plant. We are making changes to promote an operating attitude that encourages strict compliance to procedures among all our personnel. We will continue to stress the need for improved communications between personnel and between plant organizations. On August 2,1988, we met with representa-tives of Region I to discuss impending changes in key personnel and plant organization.
j A major facet of the reorganization, which occurred September 1 1988, combined the i
Nuclear Operations and Maintenance Departments to form the Calvert Cliffs Nuclear Power l
l Plant (CCNPP) Department. Therefore, the Manager-CCNPP is now in a better position to i
define common goals, clarify responsibilities, and take more effective actions to i
resolve issues important to plant safety and operation.
l t
t l
t i
l l
4 1
6
(
i I
i i
I
)
i i
1 l
l
)
i
)
- l I
1
..