ML20212Q397
| ML20212Q397 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/31/1986 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8702020245 | |
| Download: ML20212Q397 (4) | |
Text
I a
BALTIMORE GAS AND ELECTRIC l
CHARLES CENTER R O. BOX 1475 BALTIMORE, MARYLAND 21203 JostPH A.TIERNAN vict PRestormt NUCLEAR ENERGY December 31,1986 U. S. Nuclear Regulatory Commission Docket Nos.50-317 Region I 50-318 631 Park Avenue License Nos.DPR-53 King of Prussia, PA 19406 DPR-69 ATTENTION:
Mr. Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Reactor Projects Gentlemen:
This refers to Inspection Report 50-317/86-20, 50-318/86-20; which transmitted one item of apparent noncompliance with NRC requirements. Enclosure (1) to this letter is a written statement in reply to the item noted in Appendix A of your letter dated December 2,1986.
Should you have any further questions regarding this reply, we will be pleased to discuss them with you.
Very truly yo,urs,
,r - 4 v-J. A. Tie n
JAT/LSL/ dim Enclosure cc:
D. A. Brune, Esquire i
- 3. E. Silberg, Esquire S. A. McNeil, NRC T. Foley, NRC 1 l 8702020245 961231 l
PDR ADUCK 05000317 G
ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/86-20; 30-318/86-20 APPARENT FAILURE TO PROPERLY REVIEW AND TAKE ANY CORRECTIVE ACTION FOR IMPROPER COMPLETION AND/OR FAILURE OF THE ACCEPTANCE CRITERIA FOR SURVEILLANCE TESTS We have reviewed the circumstances that led to the apparent violation of Technical Specification 6.8, " Procedures," referred to by the subject inspection report.
Each instance which involved failure to properly review and take corrective action for the improper completion and/or failure of the acceptance criteria for the listed Surveillance Test Procedures (STP) is addressed individually. This is due to the unique circumstances involving each STP. Finally, our Quality Assurance Section will perform an audit of the STP program in January 1987. A random sampling of STPs will be reviewed to ensure the probiern areas noted in this inspection are not generic to our STPs.
I.
STP M-380B-0 "Hy Analyzer Calibration O-AE-6527" STP M-380B-0 requires that a measured system voltage be converted to a desired -
tolerance band in percent H2 using a formula. This band is then compared to the indicated percent H2 o determine the status of calibration. The procedure does t
not require the recording of the tolerance band. Therefore, those personnel involved in the review process (technicians / supervisors / Surveillance Test Coordinators) were making mental calculations to ensure the indicated H 2 percentage was within the required band. This in itself lef t room for personnel error.
The STP has since been reviewed by the Plant Operations Safety Review Committee (POSRC) in accordance with CCI-104 (Surveillance Test Program), and the subsequent performance of STP M-380B-0 has been performed satisfactorily.
The Surveillance Test Coordinator, supervisor, and technicians are aware of the problems which contributed to this occurrence. STP M-3808-0 will be changed to require the explicit calculation and documentation-ci the tolerance band. This will provide the technician with explicit values for comparison. Additionally, each subsequent reviewer will have an additional check of the tolerance band calcula-tion. STP M-380B-0 will be changed by February 1,1987.
II.
STP 0 28-1 "H Recombiner Semi Annual Test" 2
j The surveillance test requires the H2 recombiners be started and increased in temperature to 2 700 F within 90 minutes of start time. The H2 recombiners are then maintained at 2 700 F for two hours af ter all three thermocouples reach 700*F. - _.
2 ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/86-20; 50-318/86-20 The STP includes steps to perform this surveillance and directs that readings be taken on all three thermocouples to verify that the temperature remains greater than 700 F for the duration of the test. These readings are taken at 30,60,90, and 120 minutes af ter all three thermocouples reach 700 F. The test performed on September 18, 1986, had temperatures recorded at the specified intervals, which would indicate that the temperature was maintained for the required two i
hours.
Also recorded were the start time, the time at which all three thermocouples achieved 700 F (which was within the required 90 minutes) and the test end time. The difference in the recorded time between test end time and achieving 700 F was only one hour and forty five minutes vice the two hours required by the surveillance test. These times conflict with the other data recorded in the STP by fif teen minutes.
STP 0-58-1 "H Recombiner Refueling Test" was performed on October 24, 1986.
2 This was withm the surveillance interval period of the previous STP 0-28-1 performed on March 18, 1986. STP 0-58-1 is a more rigorous test requiring 0
verification of achieving temperatures greater than 1200 F within five hours and maintaining these temperatures for at least four hours.
The following corrective steps will be taken to avoid further occurrences:
1.
STP 0-28-1 and STP 0-28-2 data sheets will be revised to include an acceptance criteria value at test end time to ensure the time between reaching 700 F and the completion of the test is at least two hours. These will be revised by February 1987.
2.
We will develop a " Guide for Review" to be used by the Operations Surveil-lance Coordinator when reviewing STPs. This will provide a formatted review process to ensure compliance with administrative requirements and proper documentation of test results. The " Guide for Review" of completed STPs will be completed by April 1987.
3.
A summary of this occurrence, stressing the need for accuracy and correct-ness when recording data, was placed in the operators required reading book.
III.
STP 0-65-2 " Quarterly Valve Operability Verification; Operating STP 0-65-2 is a comprehensive test of valves in safety related systems in accordance with the requirements of ASME Section XI Article IWV.
During the period when STP 0-65-2 was being performed (October 1 through October 11, 1986), //22 Saltwater Pump and //12 Spent Fuel Pool Cooling Pump were out-of-service for maintenance. This prevented the performance of the saltwater pump and spent fuel pool cooling pump discharge check valves reverse flow test. All other sections of the STP were completed on October 7,'1986. The A
ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/E20; 50-318/E20 STP was signed as completed by the control room operator and the components which were out-of-service were annotated in the remarks section of the cover sheet.
Since the two out-of-service pumps were due to have maintenance completed within a day or two, the Shift Supervisor elected not to sign-off the " Supervisor Review" signature on the STP so that the check valves associated with these pumps could be tested. Although #22 Saltwater Pump was not returned to service as expected, the STP was modified to allow testing of #21 and #23 Saltwater Pump Check Valves on October 9,1986. On October 11, 1986, both Spent Fuel Pool Cooling Pump Check Valves were tested and the STP was completed, reviewed, and signed-off by the Shif t Supervisor. All results, malfunctions, and changes were reviewed by the Operations Surveillance Coordinator and presented to POSRC for review as specified in CCI-104H (Surveillance Test Program).
A summary of this occurrence was placed in the operators required reading book.
Additionally, the " Guide for Review," as described above, will include steps to ensure the review process will discover future occurrences. Finally, CCI-104H will be modified so that an STP, which tests multiple components, can be signed-off as complete in the event one of the components is out-of-service.
Those sections of the STP not completed will then be reported to POSRC.
CCI-104H will changed by June 1987.